Assignment 6 - Depo Notice

Mary's attorney wants to take the deposition of Ralph. Draft a Notice of Deposition with the following:

Draft a Deposition Notice. Your firm wants to take Ralph Cramer's deposition on March 24, 2023. Draft a Deposition Notice for the deposition to take place at 10:00am at the Beaufort City Courthouse Jury Deliberation Room. Use the sample provided as a starting point.

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HypotheticalforAssignment

Mary Martin is a property manager with the company "Real Estate 4 You", Inc. She is married to Joe Jackson, a local musician, and is the mother of two girls, Polly and Michelle, ages 4 and 6. Her business is very profitable and she makes approximately$240,000peryear.Joeisastayathomedadunlesshehasagig, whichis usuallytwiceaweek.TheMartins ownanicehomein Habershamand Mary drives a company car,a 2022Lexus whichsheuses for bothbusiness and personal trips.

Ralph Cramer is a driver for the Amazon Delivery Service Company. Ralph has been with Amazon for 10 years and is paid a good salary and receives benefits fromthecompany.Ralphisdivorcedfromhiswife,Sarahandhasjointcustodyof a young son Toby, age 5, and daughter Elly, age 2.

On October 29th 2022, Ralph was busy delivering Halloween presents around town.Hehadbeenatworksince6:30amasthisisaverybusytimefordelivery. He has been putting 12-14 hour days for the last 2 months. He stopped at the Johnson's home located at 1610 Ribaut Road at 6:15pm to drop off a massive package labeled "Gigantic Spider and Web". Usually Ralph puts on his hazard

lightswhenmakingadelivery,butwasrushedtogetoutofthetruckduetoheavy traffic and did not use the hazard lights. The sun had just gone down and it was dusk when he was making the delivery. Ralph is good friends with the Johnsons.

HepickedtheSpiderandWebupfromWal-marttobringtothemthatdayafter he finished with his other deliveries.

Mary was in a very big hurry that evening. She had been dealing with plumbing problems at two of her apartment complexes all day and wanted to get home so that Joe could go to his gig at Plum's that night. He was getting paid more than usualduetotheHalloweencrowds.Shealsohadtostopatthegrocerystore.She still had the real estate magnetic signs on the side of the car because she just left theapartmentcomplex.MarywasdrivingdownRibautwhenhercellphonerang. She looked down at the phone and saw it was the plumber. She reached for the phoneandlookedupjustintimetoseea giantboxgoflyingandthensheplowed into the Amazon delivery van. Mary's car spun out of control and came to a stop on the other side of the street when it hit a telephone pole.

Maryhas severebutnot lifethreateninginjuries. Shesuffers two brokenlegsand a broken arm, a bruised spleen and multiple bruises and lacerations. She had to undergo several operations to repair her broken bones. Ralph is also seriously hurt because Mary hit him as well as the box and Amazon van. It was fortunately a glancing blow. He suffered several injuries including a severe concussion, broken ribs and torn ligaments as well as several cuts that required a total of 55 stitches.TheGiganticSpiderandWebsetwasdestroyedandunfortunatelyitwas sold out in all stores. Mary's Lexus was totaled and the Amazon Van required expensive repairs which cost over $50,000.00. Mary was in the hospital for 10 days and missed Halloween with her husband and daughters. She and Joe also had to cancel their 10th anniversary trip to the Bahamas in early December. Joe also had to cancel all of his gigs for the next two months to take care of Jean and the girls.

Ralphwas releasedfromthehospital onHalloween,but hadto walkwitha cane, for six months. Hehadto paya nurseto comeinto change his bandages and also hadtopayforchildcarewhenhehadcustodyofhischildrenashewasunableto care for them alone for six weeks.

Marywasoutofworkforfourmonthsduetoherinjuriesand missedabig promotion because she could not attend the company's annual retreat.

Ralphwasoutofworkfor7weeksandwas restrictedtolightdutiesfor60days when he returned.

MaryhashiredyourlawfirmtopursueanactionagainstRalphandAmazon.

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Attorney for Plaintiff

Katherine Smith, Esquire

123 Oak Street

Habersham, South Carolina 12345

Tel. No.: (555) 555-5555

SC Bar No.: XXXXXXX

Email address: k..h@

ATTORNEYS FOR DEFEDANTS

Trump Smith, Esquire

678 Heaven Street

Beaufort, South Carolina 12345

Tel. No.: (843) 000-0000

SC Bar No.: XXXXXXX

Email address: t..p@

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Use the Examples as templates to help give you a frame for drafting these documents

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

COUNTY OF XXXXXXX ) XXXXXXXX JUDICIAL CIRCUIT

) CIVIL ACTION NO: 20xx-CP-00-0000

XXXXX XXXXXX, )

Plaintiff, )

vs. ) ) NOTICE OF DEPOSITION

XXXXXX XXXXXX XXXXXX )

XXX XXXXXXX XXXXXXXXXX, )

Defendants, )

)

____________________________________)

To:

Please take notice that, pursuant to Rule 30 in the South Carolina Rules of Civil Procedure, the undersigned will take the deposition upon oral examination of Jane Witness. The deposition will begin at 11:00 AM on Wednesday XXXXX XX^th, XXXX at the office of Attorney XXXXX XXXX, 123 ABC Street, Anytown AS XXXXX. Said deposition shall continue form day-to-day until completion, shall be recorded by sound or stenographic means and shall be before a Notary Public or other individual qualified to administer oaths. You are invited to attend and participate as provided by the South Carolina Rules of Civil Procedure.

This xxst day of XXXXX, 2023.

___________________________________

XXXXX XXXXX, Esquire

Attorney for the XXXXXXXX

Street Address

City/Town, State XXXX

Tel. No.

SC Bar No.

Email address

[Name] is requested to bring and make available for inspection those documents identified in Exhibit A attached hereto.

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

COUNTY OF XXXXXX ) XXXXXXXX JUDICIAL CIRCUIT

) CIVIL ACTION NO:

XXXXXXX XXXX, )

Plaintiff, ) CERTIFICATE OF SERVICE

vs. )

XXXXXXXX XXXXXXXXXXXXX, )

Defendant, )

)

____________________________________)

I, XXXX XXXXX, title, do hereby certify that on date , I served, upon the party noted below, a copy of the Notice of Depositionvia electronic mail and United States Mailin an envelope properly addressed, with sufficient postage affixed to ensure proper delivery to the following:

Attorney name, Esquire

Attorney for XXXXX

Street Address

City/Town, SC XXXXX

email

______________________________

XXXXX XXXXX, Esquire

Attorney for the XXXXXXXX

Street Address

City/Town, State XXXX

Tel. No.

SC Bar No.

Email address

City/Town, South Carolina

XXXXX XX, 2023