February 19, 2001


Dear Dr. X: Enclosed is a copy of a Notice to Take Deposition Duces Tecum and a Subpoena. This will, or has been served on you. I will be taking your deposition on


, 2001 and will be paying you $______ for your time. I will not pay for time


spent at your deposition waiting for the material to be produced. Please gather and copy, or review and summarize the material requested prior to the deposition to avoid any waste of time. If an employee or other service can provide more accurate information than you can, please have [Defense Attorney] provide me with those names and availability and I will depose that person as well. Thank you for your anticipated cooperation.


Very Truly Yours,


Enclosures cc:Defense Counsel Insurance Company


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Notice to Take Deposition Duces Tecum The Plaintiff, pursuant to the Maryland Rules of Civil Procedure, will take the deposition of


for discovery and/or use at trial on , M.D., , 2001 at 29 West Susquehanna Avenue, Suite 302, Towson, Maryland 21204.


This deposition will continue from day to day until completed. Pursuant to the Maryland Rules, the deponent is requested deponent bring the following documents to the deposition: For the previous ten (10) years, all tax returns, W2’s, financial statements, 1099’s, or any other writing or document of any kind that refers to or reflects any income to the deponent, or to any entity, including but not limited to, a corporation, partnership or professional association at which the deponent is employed (from which the deponent derives income either directly or indirectly), for income derived from the following areas: review of records,


testimony at deposition or trial, forensic activities, Independent Medical Exams (“IME’s”), examinations conducted on any person not a patient, preparation for IME’s, depositions or trial, research in connection with any forensic assignment. Any document or writing that reflects the nature of any entity that bills for professional services performed by the deponent.


All contracts, writings, or agreements between this deponent and any insurance carrier, which reflects or relates to forensic activities or medical examinations of persons who are not patients. All policies, procedures, or guidelines in place in any professional office occupied by the deponent that refer, reflect or relate to the billing procedures utilized by the deponent for forensic or IME activity.


With respect to Insurance Company, all bills, or a summary of the bills for forensic or IME


related activity on behalf of that insurance company in the last five (5) years. All bills generated and/or issued by the deponent and/or any related entity for work done relating to this case. All records, reports, correspondence, documents or writings supplied to the deponent in connection with this case. All reports, notes, memos, documents or writings generated by this deponent in connection with this case, including any drafts.


A copy of any treatise, article, book, document or other writing reviewed by the deponent in connection with this case, or relied upon in the formulation of any opinions held in this case.


All of your curriculum vitas for the past five (5) years, up to and including the most recent version. A copy of any record or writing regarding any disciplinary proceeding in which the deponent was a party. Any pleading or other document for any proceeding in which the deponent was a party. All publications by the deponent, which refer or relate to the allegations or issues in this case.


Your complete file concerning the Plaintiff and/or this case. (With this Notice, a subpoena for the same records should be served on the deponent.)


Spring 2001 Trial Reporter 13 .


With respect to ______________ [Law Firm], all bills, or a summary of the bills for forensic or IME related activity in the last five (5) years in cases in which an attorney from [Law Firm] was involved.


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