My name is XXXXX XXXXX I'd be happy to answer your questions today.
There's no need to work with opposing counsel, unless you'd like to choose mutually agreeable dates for the deposition. The primary benefit to doing this is that you don't have to worry about rescheduling and having to re-notice everyone, which can save you some time and energy. A party can send a subpoena
with a deposition notice, telling the individuals when and where to show up. Deposition notices are not filed with the court. The other party does get a copy, and they'll have to move to quash the subpoena if they do not want the depositions to occur.
The Rule that governs depositions is 1.310
1) A party desiring to take the deposition of any person upon oral examination shall give reasonable notice in writing to every other party to the action. The notice shall state the time and place for taking the deposition and the name and address of each person to be examined, if known, and, if the name is XXXXX XXXXX a general description sufficient to identify the person or the particular class or group to which the person belongs. If a subpoena duces tecum is to be served on the person to be examined, the designation of the materials to be produced under the subpoena shall be attached to or included in the notice.
(2) Leave of court is not required for the taking of a deposition by plaintiff if the notice states that the person to be examined is about to go out of the state and will be unavailable for examination unless a deposition is taken before expiration of the 30-day period under subdivision (a). If a party shows that when served with notice under this subdivision that party was unable through the exercise of diligence to obtain counsel to represent the party at the taking of the deposition, the deposition may not be used against that party.
Here is a sample deposition notice that may help.
Typically, you'll want to hire a stenographer to make a transcript of the deposition so you'll have it for your records. You should be able to find someone local online, or you could see if the clerk's office has a list. The Rule also allows a party to make a video recording of the deposition. The notice must mention the video recording and say who is doing it, and a stenographer must make a transcript, if you do that. For more information, if you want to videotape, take a look at the rule.
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