Janson et al v. LegalZoom.com, Inc.

Filing 39

NOTICE to take deposition of LegalZoom.com, Inc. filed by James J. Simeri on behalf of Plaintiffs Gerald T. Ardrey, C & J Remodeling LLC, Chad M Ferrell, Todd Janson.(Simeri, James)

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MISSOURI CENTRAL DIVISION TODD JANSON, et al., Plaintiffs, v. LEGALZOOM.COM, INC. Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No. 10-04018-CV-C-NKL NOTICE OF DEPOSITION In accordance with Rule 30(b)(6) of the Federal Rules of Civil Procedure, the undersigned attorney will take the deposition of a representative of LegalZoom.com, Inc., to be taken upon oral examination before a shorthand reporter and notary public duly authorized to administer oaths. Any party or their attorney may attend and participate as they see fit. The deposition will continue day-to-day until completed. DATE AND TIME OF DEPOSITION: PERSON BEING DEPOSED: PLACE OF DEPOSITION: August 3, 2010 at 10:00 a.m. Representative of LegalZoom.com, Inc. Bryon Cave LLP One Kansas City Place 1200 Main Street, Ste. 3500 Kansas City, MO 64105 TOPICS OF EXAMINATION: See Exhibit A attached. BUTSCH SIMERI FIELDS LLC Edward D. Robertson, Jr., # 27183 Mary Doerhoff Winter, # 38328 BARTIMUS, FRICKLETON, ROBERTSON & GORNY 715 Swifts Highway Jefferson City, MO 65109 573.659.4454, 573.659.4460 (fax) chiprob@earthlink.net marywinter@earthlink.net Randall O. Barnes, #39884 RANDALL O. BARNES & ASSOCIATES 219 East Dunklin Street, Suite A Jefferson City, Missouri 65101 573.634.8884, 573.635.6291 (fax) rbarnesjclaw@aol.com Timothy Van Ronzelen, #44382 Matthew A. Clement, #43833 Kari A. Schulte, #57739 COOK, VETTER, DOERHOFF & LANDWEHR, PC 231 Madison Jefferson City, Missouri 65101 573.635.7977, 573.635.7414 (fax) tvanronzelen@cvdl.net mclement@cvdl.net kschulte@cvdl.net _/s/_David T. Butsch________ David T. Butsch, # 37539 James J. Simeri, #52506 231 S. Bemiston Ave., Ste. 260 Clayton, MO 63105 314.863.5700, 314.863.5711 (fax) butsch@bsflawfirm.com simeri@bsflawfirm.com Steven E. Dyer, #45397 LAW OFFICES OF STEVEN DYER 10850 Sunset Office Drive, Ste. 300 St. Louis, MO 63127 314.898.6715 jdcpamba@gmail.com Attorneys for Plaintiffs 2 CERTIFICATE OF SERVICE I certify that on July 23, 2010, I served this paper by mail as follows: Party Counsel Robert M. Thompson James T. Wicks BRYAN CAVE LLP One Kansas City Place 1200 Main Street, Ste. 3500 Kansas City, MO 64105 816.374.3200, 816.374.3300 (fax) John Michael Clear Michael Biggers James Wyrsch BRYAN CAVE LLP One Metropolitan Square Ste. 3600 211 N. Broadway St. Louis, MO 63102 314.250.2000, 314.259.2020 (fax) Defendant LegalZoom.com, Inc. ___/s/__David T. Butsch___________ 3 EXHIBIT A INSTRUCTIONS AND DEFINITIONS 1. Unless otherwise noted, the time period encompassed by the following topics is limited to the period December 17, 2004 to the present. 2. The geographic scope of the following topics shall be limited to Defendant's customers residing in the State of Missouri. WITNESS(ES) TO BE DEPOSED An officer, director, managing agent or other representative of Defendant to testify on behalf of Defendant regarding the following subject matters: 1. A description of all services provided by Defendant relating to the preparation of legal documents, including, but not limited to, services relating to the following: (a) (b) (c) (d) (e) (f) (g) (h) (i) formation of business entities; the creation of wills, living trusts and powers of attorney; the preparation of trademarks, patents and copyrights, divorces and name changes; contracts; bankruptcies; real estate transactions: small claims: and, prenuptial agreements. 2. The method(s) by which the documents subject to a fee are prepared, including the Defendant's use of any computer or software program in the preparation of such documents. 3. The number of transactions in which Defendant received payment from a customer for the provision of services relating to the preparation of legal documents and the total amounts of such payments received. 4 4. The content of the database containing customer data as referred to in paragraph 5 of the declaration of Edward R. Hartman dated February 3, 2010. 5. The content of the report referred to in paragraph 7 of the declaration of Edward R. Hartman dated February 3, 2010. 6. 7. Defendant's document retention policies. The named Plaintiffs' transactions with Defendant. 8. Defendant's maintenance of tapes, discs or other computer readable medium which include all or part of the following data: (a) (b) (c) (d) 9. the identity and address of the person or entity to whom a fee was charged; the dollar amount of the fee; the date the fee was charged and payment received; and a description or designation of the service provided. The structure of Defendant's organization. 5

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