West Palm Beach Car Accident MISCELLANEOUS PETITION FOR PERPETUATION OF TESTIMONY

Now comes (insert name of client) and hereby petitions this Court to preserve the testimony of (insert name of witness) concerning an accident which occurred on (insert date of accident). Upon information and belief, (insert name of witness) has first-hand knowledge of the facts surrounding the accident, the injuries sustained by (insert name of client), and other relevant and pertinent information relating to the claims that may be filed against certain defendants.

The Petitioner seeks to obtain deposition testimony from (insert name of witness). Petitioner's attorney has been informed that (insert brief description of why the witness may not be available for testimony at a later date).

The West Palm Beach Car Accident Petitioner submits that it is necessary to obtain this deposition testimony in order to evaluate potential claims which the West Palm Beach Car Accident Petitioner may have against certain defendants arising out of the accident previously mentioned, to prepare adequately for trial, should a suit be filed, and to preserve testimony.

WHEREFORE, West Palm Beach Car Accident Petitioner requests that an Order be entered allowing a deposition to be taken of (insert name of witness) under the guidance of this Court and under any specific conditions set forth by the Court. West Palm Beach Car Accident Petitioner submits that should the court grant this Petition, West Palm Beach Car Accident Petitioner would be amenable to a videotape deposition and would request that the Court order same.

West Palm Beach Car Accident Petitioner,

By His Attorneys,

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(Signatures of Attorneys)