Deposition by Written Questions?

by Rebecca Callow

Sep 22, 2009

I have been assigned a job that is entitled Deposition by Written Questions.

Does anyone know what this is and/or give me some information about what is expected of me? I have never heard of this and the firm I am doing it for doesn't have a clue.

I have a list of questions which have blank lines underneath as if someone is supposed to write in the answer, similar to interrogatories.

The dep notice says "will take the deposition by written questions..."

"...taken by a Court Reporter with (firm name)..."

Thanks.
Load Previous Replies
  • up

    Rebecca Callow

    Thanks for all the stories and info!! I think we should get paid more too since we're doing double duty. I guess I'll have to see how much I make on this one and then decide if I will ever do this type of dep again in the future.

    The firm that called me said they tried all day to get it covered and could not. I'm thinking that's a bad sign. But since I'm new in town and merely on their "overflow" list and not one of their regular reporters, saying "yes" can only go in my favor.
    2

    Sep 23, 2009

    • up

      Lisa Breiter

      This is a great way to take a deposition, no objections! I wish they were all like this.

      You are in a room with the witness, you swear them in. Some reporters will read the questions, but I have the witness read the questions slowly and I take it down and then you just report whatever answer the witness gives. Usually they are very short and the witnesses are record custodians and they know how to testify.

      Have fun!

      Sep 24, 2009

      • up

        Mikayla Speegle

        Hi!  I was asked to do this as well, but was not provided a sealed envelope of questions pursuant to CCP 2025.330e. 

        Can you take a depo by asking written questions to the deponent without the questions being in a sealed envelope?  Also, can the other side object or ask questions after I am done reading the questions and the witness is done answering them?

        Here is the CCP:  (e) "In lieu of participating in the oral examination, parties may transmit written questions in a sealed envelope to the party taking the deposition for delivery to the deposition officer, who shall unseal the envelope and propound them to the deponent after the oral examination has been completed."

        Jun 8, 2022