Fill and Sign the Mississippi Rule of Civil Procedure 30b Casetext Form

IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI JUDICIAL DISTRICT PLAINTIFF VS. NO. DEFENDANTS NOTICE TO TAKE DEPOSITION TO: Please be advised that Plaintiff will take the Deposition of , pursuant to Rule 30(b)(6) of the Mississippi Rules of Civil Procedure on the day of , 20 , at : a.m./p.m. and continuing until completed. The Deposition of will take place at the office of or at such other place as the parties may agree. shall designate one or more persons who are knowledgeable about and who will be questioned regarding the following matters: 1. The contention of that and were not agents of during the relevant period of time regarding Plaintiff's Complaint. 2. All facts and circumstances surrounding the cancellation of Worker's Compensation Policy No. including, but not limited to, all documents generated by in regard to said cancellation, all persons involved in the cancellation decision and correspondence or other communication between and and/or or . 3. All facts and circumstances regarding the cancellation, premiums paid, return premiums due and amounts withheld from return premiums due in regard to Policy No. issued to Plaintiff, . 4. All facts and circumstances to support your contention that if a portion of the return premiums due on Policy No. was wrongfully withheld that such withholding was done under the earnest and good faith belief that any such sum was due in commissions to . 5. The names and addresses of all persons at who had anything to do with the following: (a) Cancellation of Worker's Compensation Policy No. . (b) Calculations of the return premium due under Policy No. . (c) Servicing Policies referenced in subparagraphs (a) and (b). (d) Issuance of policies referred to in subparagraphs (a) and (b). (e) Premium collection for the policy referred to in subparagraphs (a) and (b). is requested to produce for inspection and copying at said deposition pursuant to the Mississippi Rules of Civil Procedure the following documents: 1. All files maintained by Travelers or in its possession regarding Workers Compensation Policy No. issued unto Plaintiff, . 2. All files maintained by or in its possession regarding Policy No. issued to . 3. All files maintained by in regard to its relationship to and/or particularly as it relates to any agency relationship, claims made in regard to the subject Insurance Policy, Agency Agreements, etc. 4. A copy of any and all correspondence, memorandums or other matters regarding Policy No. directed to , , or or any other person or corporation including, but not limited to, in-house correspondence and memorandums. 5. Any and all correspondence, memorandums, or documents relating to Policy No. issued to directed to , or any other person or corporation, including in-house correspondence, memorandums and other documents. 6. All documents of any kind to reflect the amount of refund paid to on Policy No. and the amount of refund withheld and the basis for withholding same. 7. All documents of any kind to support your withholding a portion of the return premium due under Policy No. allegedly due , including in-house memorandums, notes, correspondences and any outside or inside opinions rendered to you regarding same. 8. All documents, correspondence or any memorandum of any kind generated between the date cancelled Policy No. and the date of the issuance of the return premium. 9. Any and all information contained on any computer regarding the subject Worker's Compensation Policy and Liability Policy in the form of computer printouts, computer disks or direct access to a computer. 10. A copy of the subject insurance policies. Respectfully submitted, ______________________________ ______________________________ CERTIFICATE OF MAILING I, do hereby certify that I have mailed this day by U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing Notice to Take Deposition to Dated this the day of , 20 . ______________________________