| name | deposition-notice |
| language | en |
| description | Drafts U.S. deposition notices (party, non-party subpoena, Rule 30(b)(6)), cover letters, scheduling letters, and proofs of service. Use when preparing or serving deposition notices or subpoenas in federal or state court. Triggers: deposition notice, notice of deposition, 30(b)(6), corporate representative, subpoena, subpoena duces tecum, AO 88A, witness fee, proof of service, scheduling letter. |
Deposition Notice Package
Draft compliant deposition notices, subpoenas, and related service documents for federal or state discovery.
Quick Start
- Gather inputs via the intake table below.
- Match deponent type to the document-selection matrix.
- Apply federal baseline checks (adjust for local rules).
- Generate documents from templates; attach exhibits as needed.
- Run the pre-service checklist; calendar all deadlines.
Intake
| Field | Notes |
|---|
| Court / Case No. | Include case caption and parties |
| Deponent type | Party, non-party, or Rule 30(b)(6) org |
| Deponent name / address | Plus counsel if represented |
| Date / time / time zone | |
| Location or platform | Physical address or remote link |
| Recording method | Stenographic, video, audio, or hybrid |
| Document requests | Subject matter and date ranges |
| Issuing court (subpoena) | Non-party only |
| Witness fee / mileage | Non-party only |
| Service method / date | |
Document Selection
| Deponent Type | Documents |
|---|
| Party witness | Notice of Deposition, Scheduling letter (optional), Proof of Service |
| Non-party witness | Subpoena (official form, e.g. AO 88A), Exhibit A (if docs), Cover letter, Proof of Service |
| Rule 30(b)(6) org | 30(b)(6) Notice with topic list, Exhibit A (if docs), Proof of Service |
Federal Baseline Checks
Adjust for state and local rules. Items marked [VERIFY] require jurisdiction-specific confirmation.
| Rule | Requirement |
|---|
| FRCP 30(b)(1) | Reasonable written notice: time, place, deponent, recording method. 10-14 days common [VERIFY local rules]. |
| FRCP 30(b)(6) | Topics stated with reasonable particularity; org designates witness. |
| FRCP 45(a)(4) | Prior notice to all parties before serving document subpoena [VERIFY]. |
| FRCP 45(b)(1) | Tender witness fee and mileage at service (non-party). |
| FRCP 45(c)(1) | 100-mile / in-state travel limits [VERIFY]. |
| FRCP 45(d)(2)(B) | Objections due within 14 days or before compliance [VERIFY]. |
| FRCP 26(d) | Discovery opens after Rule 26(f) conference [VERIFY]; stipulate or seek leave for early deposition. |
Templates
Adapt all templates to jurisdiction and local rules.
Notice of Deposition (Party)
[COURT CAPTION]
NOTICE OF DEPOSITION OF [DEPONENT NAME]
TO: [OPPOSING COUNSEL NAME AND ADDRESS]
PLEASE TAKE NOTICE that [NOTICING PARTY] will take the deposition of
[DEPONENT NAME] on [DATE] at [TIME] [TIME ZONE], at [LOCATION] or via
[REMOTE PLATFORM].
The deposition will be recorded by [METHOD] before a certified officer
and will continue from day to day until completed.
[Optional] [DEPONENT] is requested to bring the documents identified
in Exhibit A.
Dated: [DATE]
[LAW FIRM]
By: ______________________
[ATTORNEY NAME] [ADDRESS] [PHONE] [EMAIL]
Rule 30(b)(6) Notice
[COURT CAPTION]
NOTICE OF RULE 30(b)(6) DEPOSITION OF [ORGANIZATION]
TO: [OPPOSING COUNSEL NAME AND ADDRESS]
PLEASE TAKE NOTICE that [NOTICING PARTY] will take the deposition of
[ORGANIZATION] pursuant to FRCP 30(b)(6) on [DATE] at [TIME] [TIME ZONE],
at [LOCATION] or via [PLATFORM].
[ORGANIZATION] shall designate one or more persons to testify regarding:
TOPIC 1: [Reasonable particularity]
TOPIC 2: [Reasonable particularity]
TOPIC 3: [Reasonable particularity]
[Optional] The designee(s) shall bring the documents identified in Exhibit A.
Dated: [DATE]
[LAW FIRM] / [SIGNATURE BLOCK]
Subpoena (Non-Party)
Use the official court form (AO 88A for federal). Issue from the court where the deposition will occur. Attach Exhibit A for document requests.
Exhibit A — Documents to Produce
EXHIBIT A - DOCUMENTS TO BE PRODUCED
1. All documents relating to [subject] from [date range].
2. All communications with [person/entity] regarding [subject].
3. All records of [specific category] for [date range].
Cover Letter (Non-Party)
[DATE]
[WITNESS NAME AND ADDRESS]
Re: [CASE NAME] - Subpoena for Deposition
Enclosed is a subpoena for your deposition on [DATE] at [TIME] [TIME ZONE],
at [LOCATION] or via [PLATFORM]. [If applicable: Exhibit A lists documents.]
Enclosed is a check for witness fee and mileage: $[AMOUNT].
[ATTORNEY NAME]
Scheduling Letter
[DATE]
[OPPOSING COUNSEL]
Re: Deposition of [DEPONENT]
Please provide available dates over the next [TIME PERIOD]. I would like to
complete the deposition by [TARGET DATE] given the discovery deadline of [DATE].
Proposed dates: [DATE 1], [DATE 2], [DATE 3].
Proof of Service
PROOF OF SERVICE
I declare under penalty of perjury that on [DATE] I served [DOCUMENTS]
on [RECIPIENTS] by [METHOD] at [ADDRESSES/EMAILS].
[NAME] [SIGNATURE] [DATE]
Pre-Service Checklist
Special Situations
- Remote deposition: Include platform URL, access instructions, tech requirements, and recording method.
- Expedited deposition: Obtain stipulation or move for leave [VERIFY].
- Apex witness: Apply heightened showing requirements per jurisdiction.
- Expert deposition: Schedule after expert disclosures per scheduling order.
Common Pitfalls
- Never notice a non-party without a subpoena.
- Overbroad 30(b)(6) topics invite objections — meet and confer first.
- Always state time zone and platform for remote appearances.
- Document requests must be proportional and tied to claims/defenses.
- Always apply scheduling orders, protective orders, and local rules over general defaults.
Cross-References
deposition-30b6-corporate-rep — detailed 30(b)(6) guidancedeposition-apex-witness — apex doctrine requirementsdeposition-preparation — witness preparation workflow
Key changes from original:
- Frontmatter: Tightened description to ~2 sentences of what + when; moved keyword list to a compact
Triggers: line; removed tags (not in the spec's required frontmatter)
- Structure: Reorganized into Quick Start → Intake → Document Selection → Checks → Templates → Checklist → Pitfalls flow matching the authoring-skills pattern
- Conciseness: Eliminated the redundant "Output Structure / Process" section (merged into Quick Start), collapsed "Output documents" list (already covered by Document Selection matrix), and merged "Guidelines" into "Common Pitfalls"
- Tables: Consolidated the 3-column federal checks table into 2 columns by folding notes into the requirement cell
- Templates: Preserved all six templates verbatim (legal accuracy) with minor whitespace tightening
- Checklist: Unified into a single "Pre-Service Checklist" with conditional items marked
(if applicable) instead of separate conditional bullet groups
