MAKE THEM DESIGNATE A DEPONENT
Posted: Wed Dec 14, 2005 9:32 pm
If other defendants are still in the case, then make the settling party designate a deponent, who will appear at a specified place and location per a soecific notice of depo duces tecum with areas of inquiry for the purpose of providing a deposition to help you in your remaining claims. Pin them down and make it part of your settlement agreement. Make them put in writing that the attorney will coordinate and no subpoena or SDT will be required.