Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / depo-outline-franklin-orde.docx
depo-outline-franklin-orde.docx
Parties
HARKNESS LLP
Tidewater Risk Advisors LLC
Verimark Hospitality Group Inc
Ironclad Indemnity Corp
Stanton LLP
Pinnacle Surplus Lines Inc
Kraus LLP
Sovereign Re Ltd
Dates
August 25, 2023
August 28, 2023
September 18, 2022
November 1, 2023
June 20, 2023
July 1, 2022
July 1, 2023
July 28, 2023
July 1, 2021
September 22, 2022
Amounts
$15
$25
$980,000
$60
$500,000
$10
$40
$50
$25,000,000
$980,000 1
Obligations
As a threshold matter, we must confirm that Orde was the lead broker responsible for placing and servicing VHG's property insurance program, including the July 2022 renewal
We must confirm what Orde communicated to Sandra Pellegrini and other VHG personnel about the deletion of the sub-limit
Every factual detail matters here, and the testimony must be sufficiently detailed and specific to withstand scrutiny on summary judgment
KEY TESTIMONY WE NEED FROM THIS WITNESS To summarize, the following are the essential pieces of testimony that must be obtained from Franklin Orde during this deposition: 1
This testimony must be specific enough to withstand summary judgment scrutiny — i
it must identify the Ironclad underwriter who agreed, the date of the agreement, the manner in which the agreement was communicated, and any conditions attached