Janson et al v. LegalZoom.com, Inc.
NOTICE to take deposition of Richard F. Waigand filed by James T. Wicks on behalf of Defendant LegalZoom.com, Inc..(Wicks, James)
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MISSOURI
TODD JANSON, GERALD T. ARDREY, CHAD M.
FERRELL, and C & J REMODELING LLC, on behalf of
themselves and on behalf of all others similarly situated,
Case No. 2:10-cv-04018-NKL
NOTICE TO TAKE DEPOSITION DUCES TECUM
OF RICHARD F. WAIGAND, CPA
NOTICE IS HEREBY GIVEN that Defendant LegalZoom.com, Inc., will take the
deposition upon oral examination of Richard F. Waigand, on July 6, 2011, at the offices of
Butsch Simeri Fields LLC, 231 S. Bemiston Ave., Suite 260, Clayton, MO
deposition will be taken before an officer authorized to administer oaths, and will be
stenographically transcribed by a certified court reporter. The deposition will begin at 1:00 p.m.,
and will continue from day to day until completed or adjourned.
Defendant requests that Mr. Waigand bring with him to the deposition the documents
requested in Exhibit A attached to this Notice.
BRYAN CAVE LLP
s/ James T. Wicks
Robert M. Thompson
James T. Wicks
One Kansas City Place
1200 Main Street, Suite 3500
Kansas City, MO 64105
Tel.: (816) 374-3200
Fax: (816) 374-3300
John Michael Clear
Michael G. Biggers
One Metropolitan Square – Suite 3600
211 North Broadway
St. Louis, MO 63102
Tel.: (314) 259-2000
Fax: (314) 259-2020
Attorneys for Defendant LegalZoom.com, Inc.
CERTIFICATE OF SERVICE
I hereby certify that on June 29, 2011, I electronically filed the above and foregoing with
the clerk of court using the CM/ECF system, which will send notice of electronic filing to all
counsel of record.
s/ James T. Wicks
The terms “YOU” or “YOUR” means Richard F. Waigand and anyone acting or
purporting to act on your behalf, including your agents, employees or representatives.
The terms “THIS ACTION” or “THIS MATTER” mean the lawsuit under which
this Notice is filed, captioned Todd Janson, et al., v. LegalZoom.com, Inc., Case No. 2:10-cv04018-NKL, currently pending in the United States District Court for the Western District of
The term “PLAINTIFFS’ ATTORNEYS” means attorneys for the named
plaintiffs and class members in Todd Janson, et al., v. LegalZoom.com, Inc., Case No. 2:10-cv04018-NKL, currently pending in the United States District Court for the Western District of
The term “DOCUMENT” is to be interpreted in the broadest sense permitted
under the Federal Rules of Civil Procedure and includes tangible things and any media upon
which information is recorded, stored or placed, including without limitation paper, audiotape,
videotape, film, recordings, computer tape, computer disks or diskettes or internal computer
memory, together with programming instructions and notes, and all other instructions needed to
understand and use or interpret such tapes, recordings, disks or other materials. The term further
includes without limitation originals and duplicates or copies of all correspondence, literature,
papers, statements, memoranda, reports, notes, drafts, notebooks, manuals, diaries, work pads or
note pads, opinions, electronic (e-mail) or computer generated messages, telegrams, books,
letters, ledgers, pamphlets, brochures, financial statements, accounts, circulars, releases,
prospectuses, contracts, orders, punch cards, invoices, receipts, agreements, drawings, printouts,
graphs, charts, photographs, negatives, films, microfiche, microfilm, printed or graphic or
pictorial representations, catalogs, minutes, records, files, transcripts, communications, labels, or
any other writings or tangible objects, whether produced or reproduced mechanically,
electronically, electrically, photographically, or chemically.
The term “COMMUNICATION” means any disclosure, transfer, or exchange of
information by any means or manner, including without limitation any correspondence, writing,
memorandum, facsimile transmission, telephone conversation, oral conversation, electronic mail
(e mail) or computer messages or other electronic transmission.
The terms “AND” and “OR” are to be construed disjunctively or conjunctively as
necessary in order to bring within the scope of each request all documents that might otherwise
be construed to be outside its scope.
DOCUMENTS TO BE PRODUCED AT DEPOSITION
Your report in this action, if any.
All documents or materials provided to you relating to or regarding this action.
All documents or materials you reviewed relating to or regarding this action.
All documents or materials on which you relied in creating your report or forming
your opinions in this action.
All correspondence, emails and communications sent by you to anyone other than
Plaintiffs’ attorneys regarding this matter.
All correspondence, emails and communications sent to you from anyone other
than Plaintiffs’ attorneys regarding this matter.
All documents or materials in your possession relating to or regarding this matter.
Your current curriculum vitae.
Any engagement letter relating to or regarding this matter.
A list of all matters or actions for which you have provided an opinion in the last
ten (10) years.
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