Motion for Additional Deposition

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

________________________________

) Case No.:

_______________, )

Plaintiff, )

)

v. )

)

_______________, )

Defendant )

________________________________)

Noticing Party: ______________

Responding Party: ______________

[Address of Responding Party] _____

____________________________

____________________________

MOTION FOR ADDITIONAL DEPOSITION

The Requesting Party, by and through his attorney, hereby moves that this honorable court issue its order granting the Requesting Party the right to take a second deposition of deponent _______________, and awarding costs and attorney fees in favor of the Requesting Party against the Responding Party for the following reasons:

1. On _______________, 20 ___, the Requesting Party took the deposition, pursuant to notice, of the deponent _______________, at the offices of _______________, located at ______________________________.

2. The applicable court rules, in particular, FRCP...