IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
SARAH FOSTER - Plaintiff
CHARTWOOD HOMEOWNERS - Defendant,
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CASE NO. 05-C-05-095553
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NOTICE OF PARTIES’ ORAL DEPOSITIONS
AND DEPOSITIONS DUCES TECUM
Sarah Foster, Plaintiff, by her attorneys, pursuant to the Maryland Rules of Procedure, will take the depositions upon oral examinations of the following persons on the dates and at the times indicated, in the Office of Miller & Zois, LLC, 7310 Ritchie Highway, Empire Towers, Suite 615, Glen Burnie, Maryland, 21061.
DEPONENT: Steve Sellinger
TIME: 2:00 p.m.
DATE: September 10, 2005
The deponents is to produce the following documents at the above-listed time and place:
- Any contract, correspondence, or downloaded communications regarding any maintenance and/or snow removal service in effect at the time of Plaintiff’s injury.
- Any contract between the Defendant and any person or entity responsible for caring for the premises at the time of Plaintiff’s injuries.
- Any indemnity agreement between any of the parties to this case.
- Any indemnity agreement between any party to this case and nonparty which is relevant to the accident and injuries which have been made the basis of this suit.
- Any rules, management guidelines, operating guidelines, or other similar writing or document that purports to show operating procedures for the management, care, maintenance, repair, and service of the premises in question.
- Any and all photographs that Defendant has of the scene of the accident or the resulting injuries to the Plaintiff.
- Any and all expert reports which have been obtained from any expert and if a report has not been prepared, the preparation of a report is hereby requested.
- Copies of any and all statements previously made by Plaintiff or any other witnesses concerning the subject matter of this lawsuit, including any written statement signed or otherwise adopted or approved by the Plaintiff hereto and any stenographic, mechanical, electrical or other type of recording or any transcription thereof made by any person hereto and contemporaneously recorded.
- Any and all drawings, maps or sketches of the scene of the accident which has been made the basis of this lawsuit.
- A copy of any surveillance movies or photographs which have been made of the Plaintiff.
- All materials including, but not limited to, employee manuals, memoranda, and correspondence pertaining to safety rules and/or regulations to be followed by the employees to ensure homeowner safety on common space areas. This includes any training films and/or videotapes used by Defendant concerning homeowners’ spills and/or falls.
- All premises inspection reports or other documents relating to observation of common areas safety by any person or entity, including Defendants, for the premises in question, for a period of one (1) years prior to, and all dates subsequent to February 21, 2005.
- Copies of any and all documentation, including but not limited to clean-up orders, log books, journals, and service orders relating to the cleaning and maintenance of Defendant’s common areas, which set forth all requests for clearing of snow and ice verification that each request was completed, including the name of the employee who requested the work and the name of the person who carried out the service on February 21, 2005.
- Copies of any interviews or statements with alleged witnesses to the incident.
- Copies of all documents, communications, records and other tangible things relied upon and/or referred to in your response to Plaintiff’s Interrogatories.
- All documents that relate to monies spent by Aspen Park Homeowners Association between 1999 and 2005 regarding snow removal and common area maintenance.
- All documents that identify past and current members of the Board of the Aspen Park Homeowners Association between 1999 and 2005.
- All documents that relate to decision making process for expenditures or assessments between 1999 to 2005.
- Copies of any memoranda, correspondence, or minutes from any meetings regarding the snow removal budget from 2002 - 2005.
- Any documents regarding complaints made by any homeowners
regarding the snow removal before February 21, 20035
MILLER & ZOIS, LLC
Ronald V. Miller, Jr.
Empire Towers, Suite 1001
7310 Ritchie Highway
Glen Burnie, Maryland 21061
Attorney for the Plaintiff