IN THE DISTRICT COURT OF KING COUNTY  
STATE OF WASHINGTONWEST DIVISION, SEATTLE COURTHOUSE  
       
       
  )    
  )    
VAN KAMPEN & CROWE PLLC )    
 Plaintiff, )    
  )    
  )   CASE NO. 21-civ-21833 KCX  
Vs. )    
  )    
JASON STEVENS; AND WENDY STEVENS )    
Defendants )    
  )    
   
   

NOTICE OF 30(b)(6) DEPOSITION OF PLAINTIFF VAN KAMPEN & CROWE PLLC AND 30(b)(5)

REQUEST FOR PRODUCTION OF DOCUMENTS AND/OR TANGIBLE ITEMS

DEFINITIONS

As used in this 30(b)(6), Notice of Deposition of Plaintiff, Van Kampen and Crowe PLLC, and 30(b)(5), Request for Documents and Tangible Items, unless otherwise indicated, the following definitions shall be applicable.

“YOU” or “YOUR” shall mean the plaintiff(s) whom this discovery is directed to (in the case of the corporate plaintiff, it shall include its subsidiary and affiliated corporations) and each of their attorneys, experts, including, without limitation, contractors, subcontractors, agents and employees of experts, employees, agents or representatives and all other persons acting on their behalf.

The term “DOCUMENT” or “DOCUMENTS” shall mean and include writings of any kind, formal or informal, whether or not wholly or partially in handwriting including by way of illustration and not by way of limitation, any invoice, note, receipt, endorsement, check, bank draft, canceled check, deposit slip, withdrawal slip, order, correspondence, record book, minutes, memorandum of telephone and other conversations, including meetings, agreements and the like, diary, calendar, desk pad, scrapbook, notebook, bulletin, circular, form pamphlet, statement, journal, postcard, letter, telegram, telex, telefax, report, notice, message, analysis, comparison, graph, chart, interoffice or intraoffice communications, Photostat or other copy of any documents, microfilm or other film record, any photograph, sound recording or any type of device, computer data, any punch card, disc or disc pact, any tape or other type of memory generally associated with computers and data processing (together with the programming instructions and other written material necessary to use such punch card, disc, or disc pact, tape or other type of memory and together with printouts of such punch card, disc, or disc pact, tape or other type of memory; including:

  • every copy of each document which is not any exact duplicate of a document which is produced,

(b) every copy which has any writing, figure or notation, annotation or the lack of it, (c) drafts,

  • attachments to or enclosures with any document,
  • every document referred to in any other document,
  • all original file folders in which each such document is contained.

AGENCY 30(b)(6)

Defendants request TESTIMONY from the person or persons with your company most knowledgeable with respect to the following categories:

(1) The history of doing business with defendants and Mr. Al Van Kampen, and Van Kampen & Crowe PLLC.

(2) Meetings, discussions, communications, correspondence and/or contacts between you and defendants, employees, Van Kampen & Crowe PLLC attorneys, contractors, outside attorneys, experts, collection agency, collection service, collection attorneys (both internal and external), bill of sale for any debt, debt charge offs or write offs, debt sale receipts, and malpractice insurance policy.

(3) Complaints, claims, lawsuits, settlements, wherein it was alleged that you committed malpractice, wherein it was alleged that you defrauded a customer, limited to the State of Washington, from within current through five (5) years prior to the incident made the basis of this suit.

(4) Communications, correspondence, discussions, contacts between you and any state and/or federal governmental entity concerning allegations that you defrauded a customer, in the State of Washington, from within current through five (5) years prior to the incident made the basis of this suit.

(6) Communications, correspondence, discussions, and/or contacts with representatives of any co-plaintiffs of or concerning, or relating to, the account and/or insurance made the basis of this suit, and/or plaintiffs.

(7) Communications, correspondence, discussions, contacts between you and any state and federal governmental entity concerning defendants.

(8)  Communications, correspondence, discussions, and contacts with non-parties concerning or relating to the defendants made the basis of this suit.

(9) Procedures, policies, manuals or other guidelines employed by you regarding responding to customer inquiries, handling client billings, debt management sold to collections, debt charge offs.

(11) Your contentions as to why you are not liable to defendants.

(12) All contracts of insurance with plaintiffs.

(13) All files maintained on plaintiffs and/or the insurance/account made the basis of this suit.

(14) Your document retention policy.

(15) Your response to interrogatories and requests for production.

(16) Your interoffice memoranda, intraoffice memoranda, or similar internal communications and/or correspondence concerning defendants, and the account made the basis of this suit.

(17) Any minutes of any meeting referring or relating to plaintiffs and/or the insurance/account made the basis of this suit.

(18) Meetings between you, on the one hand, and plaintiffs on the other and/or any co-defendant and/or Mr. Joel C. Merkel of Merkel Law Office, whether collectively or individually.

(19) All activity on account made the basis of this suit.

(20) Instructions, directions or orders to dishonor checks made on the account made the basis of this suit.

(21) Reviews, evaluations, analyses, and studies concerning the plaintiffs and/or the account made the basis of this suit.

(22) Documents and/or tangible items reviewed by you in preparation of your deposition.  

(23) The documents requested from you in defendant’s request for production of documents and/or tangible items.

DOCUMENTS AND/OR TANGIBLE ITEMS TO BE

PRODUCED PURSUANT TO 30(B)(5)

Defendant’s request Van Kampen and Crowe PLLC to produce for inspection and copying documents and/or tangible items with respect to the following categories:

(1) The history of doing business with defendants.

(2) Meetings, discussions, communications, correspondence and/or contacts between you and defendants concerning service agreements, payment agreements.

(3) Meetings, discussions, communications, correspondence and/or contacts between you and Mr. Joel C. Merkel of Merkel Law Office concerning service agreements, payment agreements, debt collection services, bill of sale and receipt for defendants alleged debt.

(3) Complaints, claims, lawsuits, settlements, wherein it was alleged that you committed malpractice, defrauded a customer, limited to the State of Washington from current through five (5) years prior to the incident made the basis of this suit.

(4) Communications, correspondence, discussions, contacts between you and any state and you and any federal governmental entity concerning allegations that you defrauded a customer, in the State of Washington, within the last fifteen years.

(6) Communications, correspondence, discussions, and/or contacts with representatives of any co-defendant of or concerning, or relating to, the account and/or insurance made the basis of this suit, and/or plaintiffs.

(7) Communications, correspondence, discussions, contacts between you and any state and/or federal governmental entity concerning plaintiffs and/or any co-defendant.

(8)  Communications, correspondence, discussions, and/or contacts with non-parties concerning or relating to, the insurance/account made the basis of this suit and/or plaintiffs.

(9) Procedures, policies, manuals or other guidelines employed by you regarding procuring insurance, responding to customer inquiries, handling claims and/or underwriting a insurance.

(10) Documentation in your possession concerning the insurance/account made the basis of this suit and/or plaintiffs.

(11) Your contentions as to why you are not liable to defendants.

(12) All contracts of insurance with plaintiffs.

(13) All files maintained on plaintiffs and/or the insurance/account made the basis of this suit.

(14) Your document retention policy.

(15) Your response to interrogatories and requests for production.

(16) Your Interoffice memoranda, intraoffice memoranda, or similar internal communications and/or correspondence concerning plaintiffs, and/or the insurance/account made the basis of this suit.

(17) Any minutes of any meeting referring or relating to defendants and the account made the basis of this suit.

(19) Meetings between you, on the one hand, and plaintiffs on the other and/or any co-defendant and/or Mr. Joel C. Merkel of Merkel Law Office, whether collectively or individually.

(20) All activity on account made the basis of this suit.

(21) Instructions, directions or orders to dishonor any payments or checks made on the account made the basis of this suit.

(22) Reviews, evaluations, analyses, and studies concerning the defendants and the account made the basis of this suit.

(23) Documents and tangible items reviewed by you in preparation of your deposition.  

(24) The documents requested from you in defendant’s request for production of

documents and tangible items.

Respectfully submitted,

Dated February 21, 2022 /s/ Jason Stevens

/s/ Wendy Stevens

Jason Stevens

Wendy Stevens

1037 NE 65th Street, #80817

Seattle, Washington 98115

pro se

 

CERTIFICATE OF SERVICE

I, Jason Stevens, do hereby certify that I have this day mailed, U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing to VAN KAMPEN & CROWE PLLC, at the following address; 1001 Fourth Street Avenue, Suite 4050, Seattle, Washingtong 98154-1000.

THIS the ____ day of _____________, 2022.

_________________________________

Jason Stevens

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