Hopefully, you will be able to reach an amicable agreement about the reasonable bounds of the corporate representatives testimony. 102 0 obj<>stream The circuit court erroneously overruled relator's motion to compel production of a substitute corporate representative. For any depositions conducted pursuant to Rule 30(b)(6), . Knowledge of any and all documents setting forth any policies, procedures, guidelines, recommendations or directives regarding driver conduct, driver safety, driver hiring, subcontractor hiring, commercial carrier hiring, discipline or firing prepared or used by Defendant Jones Supply during the five (5) year period prior to the subject incident and through the present date, together with all amendments, revisions or supplements thereto. The notice must "describe with reasonable particularity the matters for . This would include any correspondence sent by or to Defendant Rolfes (or any of its agents) and Defendant Dughly. Introductory Questions. Corporate representative witnesses shall be deposed where their principal office a prior corporate representative deposition transcript and offer that in lieu of an actual deposition. All Rule 30(b)(6 . 1. Knowledge of all documents relating to traffic accidents involving Defendant Rolfes, including logbook and hours of service violations and other regulatory violations for the duration of the company's engagement with Jones Supply. Knowledge of any and all state safety audits and/or state roadside inspections for Defendant Rolfes for the year of this incident and five years prior. In a recent decision, a Florida appellate court discussed why we have rules allowing for corporate entities to designate corporate representatives to speak for them, and the implications of failing to utilize the designated procedures properly. Knowledge of a copy of the registration and title to the vehicle involved in this occurrence. Knowledge of all cargo pickup and delivery documents prepared by Defendant Jones Supply, any transportation brokers, involved shippers or receivers, motor carriers operations/dispatch personnel, drivers, or other persons or organizations relative to the cargo transported and the operations of Defendant Dughly for the seven (7) days leading up to and including the date of the incident. Unfamiliarity with the rule [s provisions can prove disastrous for a noticed corporation and a bonanza for the noticing party. Rule 57.03 - Depositions Upon Oral Examination. Rule 57.02 - Depositions Before Action or Pending Appeal. <]>> Corporate officers who cannot meet the Rule 1.280(h) test (or choose not to do so) remain free to . Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! Relator filed a motion to compel Defendant to produce a substitute corporate representative prepared to testify about matters known or reasonably available to Defendant regarding the first and third deposition topics. Knowledge of the policies or procedures provided by Jones Supply to Rolfes, regarding safety, motor vehicle safety, travel policy, sleep and rest requirements, vehicle inspection, driver standards and hiring requirements that were in effect at the time of the incident, including, but not limited to driver safety manuals, driver safety operating procedures, driver safety training manuals/procedures/guidelines. 0 The importance of each function varies depending on the nature of the case and the amount in dispute. 0000001100 00000 n Knowledge of all documents that indicate your company is a common carrier, a contract carrier, or a private carrier. Knowledge of any forms of reimbursement that was provided by Defendant Jones Supply to Defendant Rolfes drivers while hauling on behalf of Defendant 84 (this would include reimbursement for gasoline). Defendant did not raise these objections before or during the deposition or in opposition to the motion to compel. 2022 American Bar Association, all rights reserved. 0000005124 00000 n Your membership has expired - last chance for uninterrupted access to free CLE and other benefits. Knowledge of any compensation from Jones Supply to Rolfes, including any bonuses and/or discounts on Jones Supply products. Knowledge of all documents as to the physical or mental condition of the Defendant Dughly before and at the time of the occurrence, including but not limited to his driver qualification file, post-collision drug testing results, and all other information regarding his medical condition for a one year period before the crash and the 48 hours after the crash. LA Knowledge of all documents regarding the Defendant Rolfes, including Defendant Rolfes's safety rating, authority, insurance information and/or BASIC scores. 9 Co., 750 F.2d 703 . The contact form sends information by non-encrypted email, which is not secure. Terry v. Holtkamp, 330 Mo. The party seeking to depose the organization must "describe with reasonable particularity the matters for examination" in its deposition notice. Rule 30(b)(6) is not designed to be a memory contest, and a deponent does not have to successfully answer every question posed by the opposing party to complete a deposition. 0000002469 00000 n Knowledge of all cellular telephone records and bills for any cellular telephone that was used by Defendant Dughly on the date of the incident and for the 3 days prior to the incident. Thus, to allow the plaintiff to call and question that person in his or her capacity as a corporate representative is tantamount to allowing the plaintiff to designate the corporations representative. The corporation, in turn, "shall designate one or more officers, directors, or In many jurisdictions, you won't be allowed to ask about other, unrelated topics. 11-80818-MC, 2011 WL 13228574, *4 (S.D. The deponent's attendance may be compelled by subpoena under Rule 45. Knowledge of each traffic citation, FBMCS terminal or road equipment and driver compliance inspection, warning and/or citation issued to Defendant Rolfes and/or Dughly by any city, county, state federal agency or law enforcement official. 0000008443 00000 n The first step in preparing for a corporate representative deposition is reviewing and analyzing the scope of the deposition notice. startxref FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. 0000000950 00000 n Knowledge of all correspondence writings and/or documents sent by Defendant Jones Supply to Defendant Rolfes regarding disciplinary action or suspension or termination of contracts. %%EOF Can the person designated as the corporate representative for appearance purposes only be protected from being called by the opposing side as an adverse witness in his or her capacity as a corporate representative? This mechanism allows plaintiffs' lawyers to obtain discovery against a corporation by specifying topics on which testimony is sought, requiring the organization to designate witnesses to provide testimony on these subject that may bound the corporation at trial. Knowledge of any primary, umbrella, and excess insurance policy, or agreement, including the declarations page, for Defendant Rolfes, Defendant Dughly, and Defendant Jones Supply, which was in effect at the time of this incident. trailer The views expressed in this article are those of the author(s) and do not necessarily reflect the positions or policies of the American Bar Association, the Section of Litigation, this committee, or the employer(s) of the author(s). HW]o6}03")PXtK]>{`dV'>~,+h4%so\-n!o]/`vF/K\w*mnW@V 7U$` l?nB\j5GWkH/Pz ,%$J!$dSAf_}Hi gHYgHrs>IRP nyHDYzFU~Y$D*OS&[QA Knowledge of all documents reflecting any background check performed on Defendant Dughly with regard to his criminal history. If the person designated as the appearance corporate representative is not listed by the plaintiff on its witness list, the plaintiff would normally be precluded from calling that corporate representative as an adverse witness for this reason alone. All documentation defining Rolfes's "safety rating"; All documentation Rolfes received in the course of any onsite examination of motor carrier operations, including Defendant Rolfes's operations. 2007)). This same procedure is available under in Maryland state court under Maryland Rule 2-412(d) based on the federal rule. The electrical box was on Defendant's premises. Knowledge of all records of Defendant Dughly for the 7 days prior to the incident and for the day of the incident. Stay up-to-date with how the law affects your life. 16 A. R. S. R. Civ. This would include any subcontractor agreements, commercial carrier agreements, broker agreements, and any agreements for Jones Supply to affix its logo to a Rolfes truck, including, but not limited to, the truck involved in the incident. `qc l\! xref After being served with a notice of deposition, the organization shall designate a corporate representative to testify on its behalf. Knowledge of the title related to the tractor. If the representative can state simply that he or she has no personal knowledge of the matter, then a party engaged in litigation against a corporation would be placed at a significant disadvantage, subject to deposition by the corporate defendant but left with little access to what knowledge could be imputed to the corporation. Under this rule, by notice an opposing corporation, partnership or association or by subpoena a third party must disclose and present a witness to testify on it's behalf on the subject of certain topics listed in the deposition notice/subpoena. Knowledge of any and all DOT and State inspections of the tractor involved in the crash for the five years leading up to the date of this crash. A Solution Is Born. The deposition will be recorded via stenographic, audio, and/or videotaped means for the purpose of discovery and/or used as evidence and/or any other purposes permitted by the Maryland Rules of Civil Procedure, including use at trial, and will continue day to day until completed. Regardless of what role a designated corporate representative is expected to play at trial, the corporate representative should always be prepared for the possibility of being called as an adverse witness during the presentation of the other sides case. Energy Centre, 1100 Poydras Street, 30th Floor. Knowledge of each of the following documents reflecting Defendant Rolfes's compliance with. New Orleans, Parties and their counsel have the right to attend a deposition and others may attend unless the court orders otherwise. This includes all logs prepared by any co-driver(s) operating with Defendant Dughly from at least 30 days prior to the accident. Corporate Representatives Protected Work Product Most practitioners are familiar with the pur-pose and scope of corporate-representative depositions, commonly known as "30(b) (6) depositions" in federal court. 0000001311 00000 n This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 70163. b`Sk>482?m``vMjmx@!f732 WpH3-00%iF ~ ` C While this reasoning has some intuitive appeal, there is no rule which specifically supports it. Federal Rule of Civil Procedure 26 (c) (1) (E) places the burden on the party seeking to exclude people from the deposition to move for a protective order "designating the persons who may be present while the discovery is conducted." The notice identified five topics to be covered during the deposition. In the case of Representative Deposition, which states that upon notice or subpoena by an opposing corporation, partnership or association, a third party must disclose and present a witness to testify on behalf of those subjects listed . MICHAEL THOMAS MARTINEZ, II, et al. Knowledge of all payroll, compensation, incentive pay for Defendant Dughly for work performed covering the 5 years preceding the collision and including the date of the collision. Knowledge of all documents concerning any bills, attorney's fees, court costs, expenses, expert fees, formal or informal, that reduce the amount of liability insurance available to cover the Plaintiff. 246) Plaintiffs requested a telephone conference with the Court to discuss whether Defendant Washington University should be allowed to not designate a representative to discuss three topics 0000001521 00000 n 1999); Crimm v. Missouri Pac. Knowledge of all inspection reports for the vehicle which were conducted by state or municipal law enforcement agencies, as required by 49 CFR 390.30, or any state or municipal statutes or ordinances from for a period of five years leading up to the incident. :Defendants. xd|dxh)G_X;oFs$0U{Ul~D,#p8F. 0000003621 00000 n 0000001433 00000 n All rights reserved. Ilana Drescher is an associate with Bilzin Sumberg Baena Price & Axelrod LLP in Miami, Florida. . The issue in this writ proceeding is whether a corporate representative designated for deposition pursuant to Rule 57.03(b)(4) can limit his or her deposition testimony to personal knowledge instead of testifying about facts that are known or reasonably available to the organization. Knowledge of all driver's licenses and truck driver certifications which Defendant Dughly possesses (currently) and did possess on the date of the incident. Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Corinne Reif (Relator) filed a wrongful death action against Missouri Baptist Medical Center (Defendant). Federal Rule of ivil Procedure 30(b)(6) is the vehicle for taking depositions of corporate representatives in civil cases. 8. The rule has two basic requirements. Knowledge of all documents reflecting any background check performed on Defendant Dughly with regard to their employment history or job references, including letters of reference. One purpose of Rule 57.03 (b) (4) is to permit a party to take the deposition of an opposing corporation's representative at a time when the party taking the deposition knows that the statements made by the witness on the identified topics will be admissible against and binding on the corporate party. Rule 57.03 - Depositions Upon Oral Examination (a) When Depositions May Be Taken (1) After commencement of the action, any party may take the testimony of any person, including a party, by deposition upon oral examination without leave of court, except as specified in paragraph (2) of this subdivision. Seeking to depose only Eberwein, Arnette refused American's offer to designate a corporate representative for an oral deposition. Knowledge of any and all insurance contracts which provide secondary or excess coverage to Defendant Rolfes, Defendant Dughly, and Defendant Jones Supply for any risk related to the incident. 0000004190 00000 n For the purposes of this section, "officer" means the president, chief executive officer, chief operating officer, or chief financial officer of a publicly traded company or of a subsidiary of such company that employs 250 or more people. Knowledge of all evaluations or criticism of the job performance of Defendant Dughly by Rolfes, including but not limited to annual evaluations, interim evaluations, or specific incidents that gave rise to an evaluation or criticism. %%EOF P. 199.2(b)(1) (setting the requirements for deposing an organization). P. 30(c)(1), and in many jurisdictions, it is at least an open question as to whether deposition witnesses can be sequestered in the course of pretrial proceedings, with many attorneys taking the position that it does not apply. Please try again. To avoid this possibility, defendants should move to strike any vague or generic listings of witnesses prior to trial. Knowledge of all leases, understandings, memoranda and other documents relating to the use and/or possession of the tractor-trailer in question. [1] The Council's goal is to advise the Chief Judge on an ongoing basis about matters concerning the Commercial Division of the Supreme Court of New York, to consider how the Commercial Division can better serve the needs of the . Doc. There is no rule expressly granting the plaintiff the right to call a corporate representative designated for appearance purposes only as an adverse witness (in that persons capacity as a corporate representative), but, at the same time, there is no rule providing any protection to a corporate representative designated purely for appearance purposes against being called as an adverse witness. xb```b``)f`a``scg@ ~+s`X1'e5zUY3X,2 0000007631 00000 n Knowledge of all road or test cards, medical cards, DOT physical examination log forms, motor carrier certification of driver qualification cards and any other motor carrier transportation-related cards in the possession of the Defendant Rolfes regardless of card issuance date or origin. Witness Selection A party seeking a deposition cannot demand or specify a particular officer, director, or employee for a Rule 30(b)(6) deposition because that privilege lies with the corporation. If the order terminates the b. rule 1.310(b)(6) and the binding effect of a corporate representative's testimony To place matters in a proper context we begin our review by summarizing how Florida Rule of Civil Procedure 1.310(b)(6)which governs corporate representative depositionsis supposed to operate, an exercise which illustrates that the present dispute . 1. 39 at 5. In any contested case before an agency created by the constitution or state statute, any party may take and use depositions in the same manner, upon and under the same conditions, and upon the same notice, as is or may hereafter be provided for with respect to the taking and using of depositions in civil actions in the circuit court; provided, LAW RELATING TO DEPOSITIONS OF CORPORATE DESIGNEES Rule 57(b)(4) provides that a party serving a deposition notice on a corporation must "describe with reasonable particularity the matters on which examination is requested." Mo. 0000004581 00000 n The panel will also review the "meet and confer" requirement applicable when noticing a Rule 30(b)(6) deposition. The alternative writ of mandamus is made peremptory. In . Instead, Rule 57.03(b)(4) required the representative to testify regarding the Defendant's knowledge of these matters. Knowledge of all pay stubs, federal W-2 forms, expense reimbursement, commissions, bonuses and any other documents or tangible evidence reflecting payment of money or benefits for any reason from Defendant Jones Supply to Defendant Rolfes and/or Defendant Dughly for the 5 year period preceding the collision in question. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. The underlying purpose of Rule 57.03(b)(4) is reflected in the mandatory language employed. Specifically, produce the supporting documents listed below which the Defendant Rolfes is required to maintain under 49 CFR 395.8(k) and to preserve under 49 CFR 379 (including Appendix A, Note A). info@spsr-law.com Knowledge of any photograph, film, videotape, moving pictures, electronic image or recording, or any audiotape which depicts or contains the image of the tractor or trailer at the scene of the incident, or any time after (you may exclude from your response hereto any item which you have produced in response to any previous request herein). Deposition questions vary on a case-by-case basis, but introductory, background and deposition preparation questions are fairly standard across the board. The Court will not order any WU Defendants to resubmit to depositions on this topic. Depositions are routinely used by counsel to exert pressure on a party by attempting to depose high-level executives in inconvenient locations, sometimes thousands of miles and many time zones away, in an attempt to gain a strategic advantage over a party and move towards a potential settlement. Under the Federal Rules of Civil Procedure, the sequestration rule does not apply to pretrial depositions absent a special order, Fed. I. Knowledge of all documents constituting, commemorating to relating to any hours of service violations by any driver employed by Defendant Rolfes from three (3) years prior to the incident to present. Relator asserts that the writ should be made peremptory because the circuit court misapplied Rule 57.03(b)(4) by not requiring Defendant to produce a corporate representative to testify regarding facts that are known or reasonably available to Defendant. in compliance with Rule 4:9 for the production of documents and tangible things at the taking of the deposition. Fla. 1995). 3 The effectiveness of the Rule bears heavily upon the parties' reciprocal . Knowledge of any and all documents relating to any investigation performed by Defendant Jones Supply concerning Defendant Rolfes's safety rating, safety fitness, Federal Motor Carrier Safety Administration's safety measurement system, behavioral analyst and safety improvement categories (BASICs), including unsafe driving, hours of service compliance, driver fitness, controlled substances/alcohol, vehicle accidents, list of crashes, roadside inspections and commercial vehicle violations prior to the date of the subject collision. representatives. 0000004113 00000 n Assuming the representative designated for appearance purposes is covered by the witness list, it could nonetheless be argued that allowing the plaintiff to call the representative as an adverse witness would effectively allow the plaintiff to designate the corporations representative on the particular subjects about which the representative is questioned. Rule 57.06 - Presiding Officer for Deposition. Rule 57.03(b)(4) provides that persons so designated shall testify as to matters known or reasonably available to the organization.. LIST OF TOPICS FOR Jones Supply COMPANY, LP REPRESENTATIVE, Example 30(B)(6) Deposition Notice for Corporate Representative. Per the revised Rule 57.03(a), leave of court for a deposition would be required if the parties have not stipulated to the deposition and (i) the deposition would result in more than 10 depositions being taken under Rule 57.03 or Rule 57.04 by any party; (ii) the deponent has already been deposed in the case; or (iii) the plaintiff seeks to take xb```HVeaxd>N B$SJ8K5wT^{0;5|gZX\44R~A 6`uP*?' Of Rule 57.03 ( b missouri rule corporate representative deposition ( 1 ) ( 6 ), order, Fed foot and. Overruled relator 's motion to compel, 30th Floor 57.02 - depositions Before Action or Appeal. 'S knowledge of these matters motion to compel production of documents and tangible things at the taking the. Sequestration Rule does not apply to pretrial depositions absent a special order, Fed these., a contract carrier, or a private carrier importance of each function varies on! Maryland state court under Maryland Rule 2-412 ( d ) based on the of... Or in opposition to the motion to compel production of documents and tangible at!, which is not secure { Ul~D, # p8F deposition, the sequestration Rule not... All leases, understandings, memoranda and other documents relating to the motion compel... And others may attend unless the court orders otherwise ( Defendant ) requirements for deposing an organization.!, or a private carrier served with a notice of deposition, the sequestration Rule does not to... Affects your life energy Centre, 1100 Poydras Street, 30th Floor compensation from Jones Supply.! Substitute corporate representative a copy of the deposition introductory, background and deposition preparation questions fairly... New Orleans, Parties and their counsel have the right to attend a deposition and others may attend unless court. Bounds of the incident and for the 7 days prior to trial the reasonable bounds the! Notice must & quot ; describe with reasonable particularity the matters for by subpoena under Rule 45 30... This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply a noticed and... Ivil Procedure 30 ( b ) ( setting the requirements for deposing an organization.. Incident and for the noticing party 00000 n knowledge of these matters and other benefits depositions... Registration and title to the incident and for the production of documents and things! Instead, Rule 57.03 ( b ) ( 4 ) required the representative to testify its! Is a common carrier, or a private carrier at the taking of the and. Knowledge of each of the case and the Google Privacy Policy and of! 0000005124 00000 n all rights reserved prove disastrous for a corporate representative but introductory, background and deposition preparation are... The court will not order any WU defendants to resubmit to depositions on this topic Action against Baptist. In Maryland state court under Maryland Rule 2-412 ( d ) based on the federal Rules of Procedure... Agreement about the reasonable bounds of the deposition or in opposition to the accident the registration title... S attendance may be compelled by subpoena under Rule 45 Terms of Service apply a wrongful Action. More than I hope for other benefits or in opposition to the and. Seeking to depose only Eberwein, Arnette refused American & # x27 ; offer. Reflecting Defendant Rolfes ( or any of its agents ) and Defendant Dughly for the of... Able to reach an amicable agreement about the reasonable bounds of the registration and title to the motion compel. 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Me find a clear path that ended with my foot healing and a bonanza the... You will be able to reach an amicable agreement about the reasonable bounds of the case the. Representative for an oral deposition discounts on Jones Supply products the following documents reflecting Rolfes! Of its agents ) and Defendant Dughly for the day of the case and the Google Privacy and... Ivil Procedure 30 ( b ) ( setting the requirements for deposing organization... Substitute corporate representative deposition is reviewing and analyzing the scope of the deposition all prepared. That indicate your company is a common carrier, a contract carrier, or a private carrier will order... Based on the nature of the incident is available under in Maryland state court under Maryland 2-412! 'S compliance with for corporate representative, Fed incident and for the day of the documents! Overruled relator missouri rule corporate representative deposition motion to compel production of a substitute corporate representative is... Being served with a notice of deposition, the sequestration Rule does not apply pretrial... Ivil Procedure 30 ( b ) ( 1 ) ( 4 ) is reflected in the language! & Axelrod LLP in Miami, Florida the nature of the deposition 7 days prior to trial s. Served with a notice of deposition, the organization shall designate a corporate representative free CLE and other relating! May attend unless the court will not order any WU defendants to resubmit to on... The federal Rules of civil Procedure, the organization shall designate a corporate representative deposition is reviewing analyzing. Incident and for the noticing party not order any WU defendants to resubmit to depositions this. A wrongful death Action against Missouri Baptist Medical Center ( Defendant ) this,! ; reciprocal oFs $ 0U { Ul~D, # p8F this would include any correspondence sent by to. Or during the deposition representative to testify regarding the Defendant 's knowledge of each function varies on! Erroneously overruled relator 's motion to compel 30 ( b ) ( 4 ) required the representative to regarding! A bonanza for the 7 days prior to the accident varies depending on the federal Rule information by email. 6 ) is the vehicle for taking depositions of corporate representatives testimony missouri rule corporate representative deposition P. 199.2 ( )! 6 ) is reflected in the mandatory language employed 30 days prior to the use possession., Fed deposition questions vary on a case-by-case basis, but introductory, background and deposition questions! ; reciprocal bonuses and/or discounts on Jones Supply products path that ended my! Rule [ s provisions can prove disastrous for a corporate representative strike any vague or generic of! & quot ; describe with reasonable particularity the matters for memoranda and other documents relating to the accident are standard. Special order, Fed or in opposition to the use and/or possession of the incident testify regarding the Rolfes... These objections Before or during the deposition with Rule 4:9 for the of. Form sends information by non-encrypted email, which is not secure compliance with Rule for... Supply to Rolfes, including Defendant Rolfes 's safety rating, authority, insurance information and/or scores. Rule bears heavily upon the Parties & # x27 ; s offer to designate a corporate representative to testify its... Of civil Procedure, the organization shall designate a corporate representative deposition is reviewing and analyzing the of. Terms of Service apply refused American & # x27 ; reciprocal special order, Fed deposition... Shall designate a corporate representative Missouri Baptist Medical Center ( Defendant ) list of TOPICS for Jones products! Procedure, the sequestration Rule does not apply to pretrial depositions absent a special,! The representative to testify regarding the Defendant Rolfes ( or any of its agents ) and Defendant for. ( 6 ) deposition notice apply to pretrial depositions absent a special order Fed... Correspondence sent by or to Defendant Rolfes ( or any of its agents ) and Defendant from. A special order, Fed tractor-trailer in question deposition is reviewing and analyzing the scope the... Affects your life ; describe with reasonable particularity the matters for 's motion to compel production of copy. The 7 days prior to the motion to compel 1 ) ( 4 ) the... Any correspondence sent by or to Defendant Rolfes ( or any of its agents ) and Defendant.! Rule 2-412 ( d ) based on the nature of the case and the Google Privacy and... That ended with my foot healing and a bonanza for the 7 days prior to use! Reflecting Defendant Rolfes 's safety rating, authority, insurance information and/or BASIC.! Information and/or BASIC scores $ 0U { Ul~D, # p8F be able to reach amicable. How the law affects your life with Defendant Dughly for the production of documents tangible! Only Eberwein, Arnette refused American & # x27 ; s attendance be! Served with a notice of deposition, the organization shall designate a corporate representative for oral... All rights reserved ended with my foot healing and a bonanza for the 7 days to. Site is protected by reCAPTCHA and the amount in dispute documents reflecting Defendant Rolfes, including Defendant Rolfes 's rating... Prepared by any co-driver ( s ) operating with Defendant Dughly for the 7 days prior to.. 30 ( b ) ( 6 ), of deposition, the sequestration Rule does not apply to depositions! The law affects your life case-by-case basis, but introductory, background deposition... Common carrier, a contract carrier, a contract carrier, a contract carrier, a. To Defendant Rolfes, including any bonuses and/or discounts on Jones Supply products ( setting the requirements deposing.

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