The plaintiff served upon the defendant's counsel the following notice:
"To: George P. Moser, Esq.,
Please Take Notice that pursuant to Rule 3:26-1, et seq., of the Rules of Civil Practice, on Tuesday, May 22nd, 1951, at 2:00 o'clock
in the afternoon, at 15 Exchange Place, Jersey City, N.J., in Room 1110, before Ashley D. Carrick, Esq., an Attorney at Law of the State of New Jersey, we shall take the depositions of Captain Alsop, Carl Larsen, Sr., and Carl Larsen, Jr., the foreman and supervisors, employees of the defendant, and Denys Alsop, Vice President of the defendant corporation, as witnesses, upon oral examination with respect to all matters relevant to the subject matter involved in this action.
Take Further Notice that you, George P. Moser, Esq., attorney for the defendant, are required to produce the said Captain Alsop, Carl Larsen, Jr., Carl Larsen, Sr., and Denys Alsop, for the said examination at the time and place aforesaid, together with copies of all agreements with American Export Lines, Inc., covering stevedoring operations on Pier D, Jersey City, N.J., on February 23rd, 1950, and immediately prior thereto.