In Texas, does anyone have any advice on what questions to ask general contractor in deposition? We represent subcontractor. I think I have my outline completed but wanted to know if I was missing anything else.

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Why do you hate the subs?

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Hahahahah

Did you share the native XER schedule file when requested by the subcontractor?

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What type of case?

Plaintiffs counsel will probably cover most of what you need, but you’ll want to obtain information as to the GCs responsibility for the following.

-overall site safety, daily inspections, stop work authority, etc
-authenticate contract if favorable terms exist
- find out if any other subs had responsibility for digging the trench, flagging it, and or making visible
- their general reporting/investigation of accident;
- ascertain if there’s any other party responsible as my bet is the GC has cross claims for indemnity against you

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