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Go over where and when the deposition will take place, who will be present and why, and the role of the court reporter and the videographer (if the deposition will be videotaped). Also, explain the oath. Explain what a deposition is. Describe what a deposition is so that your client is familiar with the basic process.
A notice of deposition must reference the current court case for which the deposition is being requested. Therefore, the notice will typically include a full caption at the top of the notice, which identifies: The parties in the case. The jurisdiction where the case has been filed.
5 Steps for Responding to a Deposition Notice Analyze the documents that were served. ... Notify the party deponent. ... Decide whether to contact a nonparty witness. ... Object to defects in the deposition notice. ... Object to the production demand.
Under CR 30(b)(1), a party is required to give 5 days' notice for an oral deposition. CR 43(f)(1) requires a party to give 10 days' notice for the attendance of a party or managing agent at trial.
Your notice must include the name of the deponent, as well as the date, time, and location of the deposition. If the deponent is an organization, describe what matters you will be discussing, so that the organization may appoint a representative with the most knowledge of those issues.