Example Deposition Notices

Below are example deposition notices. For lawyers (and moot court students), these samples give both the form language needed to note a deposition and the types of documents you may wish the deponent to bring with them for the deposition.

You do not need permission for the witness or the party to note a deposition in Maryland. But a court will not look very kindly to a lawyer who unilaterally notes depositions without trying to secure a convenient date, time, and place for all relevant parties. There are no concrete rules for deposition location or time. The key is being reasonable. So coordinate with opposing counsel or the deponent’s attorney to schedule a mutually convenient date, time, and location for the deposition. Ensure that all necessary parties are notified.

The key components you want in your deposition notices are

1. The names, addresses, email addresses, attorney bar numbers, and telephone numbers of each attorney and who they represent.
2. The type of deposition notice should be characterized in the document title. If you are doing a videotaped deposition, make sure you make that crystal clear.
3. The date, time, and location where the questioning will occur.
4. The records the witness should bring to the deposition (duces tecum)
5. Signature block for the attorney noting the deposition.

You also need to pick a qualified court reporter to record the deposition.

• Federal Rule 30
• Maryland Rule 2-214
• California Rule 2025.210
• New York Civil Practice Law Sec. 3107