Objections to Notice of Deposition

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

________________________________

) Case No.:

_______________, )

Plaintiff, )

)

v. )

)

_______________, )

Defendant )

________________________________)

Requesting Party: _____________

Responding Party: _____________

OBJECTIONS TO NOTICE OF DEPOSITION

The Responding Party hereby objects to the Notice of Deposition issued by the Noticing Party for deponent _____________, for the following reasons:

1. The deposition of the named deponent will not relate to any claim or defense of the parties, nor will it produce any admissible evidence, nor is it calculated to lead to the discovery of any admissible evidence for the following reasons: _______________________________________.

2. The deposition notice issued by the Requesting Party is premature and, therefore, untimely because it was scheduled prior to the early meeting, which is prohibited by the applicable court rules.

   Or

   The deposition notice of the Requesting Party was issued after the discovery cut- off date contained in the applicable court rules or pre-trial orders and is, therefore...