§29.8 Strategic and Practical Considerations

• Jurisdiction: Washington

§29.8STRATEGIC AND PRACTICAL CONSIDERATIONS

CR 29 allows the parties to streamline discovery to save time and money. Note, for example, that CR 30(b)(4) and CR 30(b)(7) allow depositions to be recorded by other than stenographic means.

Practice Tip: Propose a CR29 stipulation to streamline discovery in cases in which time and cost concerns are paramount. Always obtain the stipulation in writing well in advance of the planned discovery.

Discovery stipulations can be used strategically. For example, parties may enter into a stipulation to stay discovery in the case until after the court rules on a pending dispositive motion. Such stipulations are likely to be enforced, absent circumstances such as fraud, and counsel should be aware that a court may enforce...