What to include for SC rule 30 deposition for plaintiff and defendant for this scenario below.

Old Information:

Your client is an on-duty police officer driving a marked police car the morning of January 1, 2023, at 4:55 a.m. when his vehicle was struck on the passenger side at the intersection of Hwy-376 and West Main Street. Your client, Sgt. John Lawman employed by the Town of Lexington, had to be cut from his vehicle by the rescue crew and flown from the scene to Richland Memorial Hospital. He's expected to live, but it's not clear whether he will make a full recovery. The at-fault driver was taken by ambulance to Lexington Medical Center. Officers responding to the scene smelled alcohol in an around the at-fault driver's vehicle but no alcohol containers or illegal drugs were recovered from the vehicle.

Because your client is an officer for the Town of Lexington, the town police department recused itself from the investigation and asked the S.C. Highway Patrol to oversee the investigation into the crash. The attorney on the case reports that the at-fault driver is likely to be charged with felony DUI upon release from the hospital, but that he does not have any further information about what police might have to support the charge.

New Information:

You got a tip from a neighbor of Ofc. Lawman's that the at-fault driver was seen out on the night in question as Billy Bob's Watering Hole, a dive bar located at 1234 Main Street, Lexington, South Carolina. Billy Bob's is a limited liability company incorporated in the State of South Carolina with the registered agent CT Corporation. Your private investigator went by the bar and attempted to interview the bar tender, Susie Server, but she claimed she didn't know anything and wasn't working on the night in question. Flanagan refused to answer much of our discovery, including where he was on the night in question, claiming he did not know; however, he did identify his phone carrier, Verizon, and his telephone number, 803-546-9999, and his bank, Palmetto Citizens, where he has a bank card with account number 1234-5678-91011.

Meanwhile, your client, Lawman, was discharged from Richland Memorial after several surgeries performed by Midlands Orthopedics physician, Dr. Rob Bonemender, and he is now enrolled in their physical therapy program but is not expected to make a full recovery or be able to return to service.

Finally, you received a call from Captain J.P. Highwayman letting you know that the MAIT report is finished, finds Flanagan to be the cause of the collision, and that he has been charged with felony DUI. The criminal case will be handled by an assistant in the Eleventh Circuit Solicitor's Office, but Capt. Highwayman does not yet know who?