This form is a sample letter in Word format covering the subject matter of the title of the form.
[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Opposing Party's Attorney's Name] [Opposing Party's Attorney's Firm Name] [Address] [City, State, ZIP Code] Re: Notice of Deposition — Discovery Dear [Opposing Party's Attorney's Name], I hope this letter finds you well. I am writing to provide you with a formal notice of deposition for discovery purposes in the [case name] pending before the [Court Name] in San Antonio, Texas. The details of the deposition are as follows: 1. Deposition Date: [Date] 2. Deposition Time: [Time] 3. Deposition Location: [Address or Venue] 4. Party to Be Deposed: [Name of the Individual/Entity] 5. Issues for Discovery: [Specify the subjects/topics to be covered] As per the Texas Rules of Civil Procedure, Rule 199.5, this discovery deposition seeks to obtain information, clarification, and/or admissions related to the facts and matters pertinent to this case. The scope of this deposition includes, but is not limited to, the examination of the deponent's knowledge, observations, experiences, and any documents, exhibits, or records within their possession, custody, or control that are relevant to the case. To maintain the integrity and efficiency of the deposition, please note the following guidelines: 1. Representation: The deponent may be represented by an attorney during the deposition. 2. Oath: The deponent will be placed under oath to provide truthful and accurate answers. 3. Record: A certified court reporter will be present to record the proceedings and create a written transcript. 4. Objections: Legal objections to specific questions may be raised during the deposition. 5. Confidentiality: Any confidential information disclosed during the deposition shall be subject to appropriate protective measures. 6. Length of Deposition: The deposition is anticipated to last [estimated duration]. 7. Notice of Videotaping: Pursuant to Rule 199.5(c)(4), the deposition will be video recorded in addition to the written transcript. It is essential that you confirm your client's availability for the specified deposition date and time within [number of days] days from the receipt of this notice. Additionally, please provide the names and contact information of all other persons you intend to be present on behalf of your client. If the designated date is not suitable for your client, kindly propose reasonable alternative dates within [number of days] days. In accordance with the local rules, your client is responsible for arranging and compensating the court reporter, while the expenses for the video recording shall be shared equally between the parties. It is advisable that arrangements for the court reporter and videographer be made as soon as possible to avoid any scheduling conflicts. Lastly, please bring any relevant documents, exhibits, or records in your possession, custody, or control that are reasonably related to the subject of this deposition. I kindly request that you inform your deponent of this requirement to ensure a thorough and productive discovery process. Should you have any concerns or requests pertaining to this deposition notice, please communicate them with me in writing within [number of days] days. Your prompt response is appreciated to coordinate the logistics and ensure a smooth deposition process. Thank you for your attention to this matter. I look forward to your affirmative response confirming the deposition arrangement. Yours sincerely, [Your Name]
[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Opposing Party's Attorney's Name] [Opposing Party's Attorney's Firm Name] [Address] [City, State, ZIP Code] Re: Notice of Deposition — Discovery Dear [Opposing Party's Attorney's Name], I hope this letter finds you well. I am writing to provide you with a formal notice of deposition for discovery purposes in the [case name] pending before the [Court Name] in San Antonio, Texas. The details of the deposition are as follows: 1. Deposition Date: [Date] 2. Deposition Time: [Time] 3. Deposition Location: [Address or Venue] 4. Party to Be Deposed: [Name of the Individual/Entity] 5. Issues for Discovery: [Specify the subjects/topics to be covered] As per the Texas Rules of Civil Procedure, Rule 199.5, this discovery deposition seeks to obtain information, clarification, and/or admissions related to the facts and matters pertinent to this case. The scope of this deposition includes, but is not limited to, the examination of the deponent's knowledge, observations, experiences, and any documents, exhibits, or records within their possession, custody, or control that are relevant to the case. To maintain the integrity and efficiency of the deposition, please note the following guidelines: 1. Representation: The deponent may be represented by an attorney during the deposition. 2. Oath: The deponent will be placed under oath to provide truthful and accurate answers. 3. Record: A certified court reporter will be present to record the proceedings and create a written transcript. 4. Objections: Legal objections to specific questions may be raised during the deposition. 5. Confidentiality: Any confidential information disclosed during the deposition shall be subject to appropriate protective measures. 6. Length of Deposition: The deposition is anticipated to last [estimated duration]. 7. Notice of Videotaping: Pursuant to Rule 199.5(c)(4), the deposition will be video recorded in addition to the written transcript. It is essential that you confirm your client's availability for the specified deposition date and time within [number of days] days from the receipt of this notice. Additionally, please provide the names and contact information of all other persons you intend to be present on behalf of your client. If the designated date is not suitable for your client, kindly propose reasonable alternative dates within [number of days] days. In accordance with the local rules, your client is responsible for arranging and compensating the court reporter, while the expenses for the video recording shall be shared equally between the parties. It is advisable that arrangements for the court reporter and videographer be made as soon as possible to avoid any scheduling conflicts. Lastly, please bring any relevant documents, exhibits, or records in your possession, custody, or control that are reasonably related to the subject of this deposition. I kindly request that you inform your deponent of this requirement to ensure a thorough and productive discovery process. Should you have any concerns or requests pertaining to this deposition notice, please communicate them with me in writing within [number of days] days. Your prompt response is appreciated to coordinate the logistics and ensure a smooth deposition process. Thank you for your attention to this matter. I look forward to your affirmative response confirming the deposition arrangement. Yours sincerely, [Your Name]