Stipulation

[Crystal]

What do you do if you have two witnesses for the same case, you take the first depo of witness number 1 and then the second depo of witness 2 right after, and the attorney says "Same stip." at the end of 2nd witness's depo.

Would I go back to first witness's depo and copy and paste that stipulation onto the 2nd witness's depo or leave as is saying "Same stip."

 

Both depos were taken the same day right after the other.

[Quyen]

I don't do anything, and I never copy and past the stipulation to any other depo. If the stipulation is about how to handle the original transcript, you just let your office know that info.  It's really not our problem/job to make sure their "stip" is clearly stated on each transcript.

[Crystal]

Okay. Thanks so much!! Makes sense.

[Judy]

I have a blurb I use, then copy and paste the previous stip (all as a parenthetical, so indented on both sides):

    (The following stipulation was entered into

at the deposition of {^"previous wit}, {^"previous date},

and is incorporated herein for reference:

     "MR. SMITH:  Blah, blah

     "MR. JONES:  Blah, blah.")

[Deborah M.]

I do what Judy does.

[Kyung]

I do what Judy does.  The stip is not just for the office, it's for the attonreys and the witness.  Oftentimes, the attorney doesn't remember the last quesiton they said, let alone a stip from a depo that took place a month ago.

 

Secondly, it tells the witness what to do with the transcript after they're done reading and signing.  Back to their attorney, opposing counsel, or nothing.

 

Third, it adds pages to the transcript.  Whoo-hoo.

 

 

[Quyen]

I guess I'm determined not to facilitate the stip. That's money out of my pocket, so why should I help them do it? I would rather have an additional copy than one measly extra page. I'd prefer to go without the extra, what, 4 bucks, plus or minus, tops(?).  If the original gets lost, the witness doesn't know what to do with it, the dog pees on it, so be it.  Maybe if it was done to code, none of that would've happened. *shrugs*

[Judy]

I've been doing this since '82. The So Cal Stip has been around well before I started in this profession.  I'd love to be able to change it, but that's not going to happen during my lifetime so I deal with it the best way I know.