Defendant’s Notice of Record Deposition Duces

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF VIRGINIA

NAME :

Plaintiff, :

v. : CASE NO.: 000000000000

NAME :

Defendant. :

DEFENDANT’S NOTICE OF RECORDS DEPOSITION DUCES TECUM

:

:

:

(For the Production Documents and Items Only)

YOU ARE HEREBY NOTIFIED that the Defendant, (NAME), will take the records

depositions of the below-named heath care providers for the production of documents and items,

only, as further described below on the date and at the time set opposite their names. Said

records custodian shall produce these records and items at (LOCATION OF RECORDS

PRODUCTION) before a Notary Public, or some other person authorized by law to administer

oaths, for the purpose of discovery or as evidence in this action, or both, pursuant to the Rules of

DEPONENT DATE TIME

Records Custodian for (DD/MM/YYYY) 11:00 am

(NAME OF MEDICAL PROVIDER)

(ADDRESS OF MEDICAL PROVIDER)

The deponent is requested to produce the following documents and items:

ENTIRE MEDICAL RECORD/CHART, including but not limited to Emergency

Room Notes, Ambulance Records, Admission History, Physical and Mental History,

Discharge Instructions, Consults, Physician Notes & Orders, Diagnostic Reports,

Laboratory Results, Nurse Notes, Medication Records, Progress Notes, Insurance

Information, Diagnostic Films and reports thereof for the following patient:

Patient: (PATIENT’S NAME)

DOB: DD/MM/YYYY

Dates of Service: DD/MM/YYYY – DD/MM/YYYY

IF THE RECORDS ARE PROVIDED BEFORE (DATE) YOU ARE NOT

REQUIRED TO PERSONALLY APPEAR FOR DEPOSITION.

(DEFENDANT’S NAME)

By Counsel

___________________________

CERTIFICATE OF SERVICE

I hereby certify that on this (DATE) a true copy of the foregoing Defendant’s Notice of Records

Deposition Duces Tecum with attachment was mailed, first class, postage prepaid to:

NAME OF PLAINTIFF’S ATTORNEY

ADDRESS OF PLAINTIFF’S ATTORNEY

____________________________________

(NAME OF DEFENDANT’S ATTORNEY)

NOTICE TO DEPONENT REGARDING

ALTERNATIVE COMPLIANCE

THE DEPONENT IS NOT REQUIRED TO PERSONALLY

APPEAR FOR THE DEPOSITION AS SCHEDULED PROVIDED

THE REQUESTED RECORDS AND ITEMS ARE COPIED AND

MAILED TO THE FOLLOWING BEFORE (DD/MM/YYYY):

(NAME OF ATTORNEY),(ADDRESS OF ATTORNEY);

Telephone: ___________________; Facsimile: ________________;

E-mail: _____________________________ .