To the parties who have appeared in the above cause of action,
and their attorneys of record:
YOU ARE NOTIFIED that on __________ [date], at __________
[time], __________ [plaintiff or defendant or as the case may
be] will take the oral deposition of __________ [name of party
or party-affiliated deponent], the __________ [plaintiff or
defendant or as the case may be] in this action, at __________
[the office of __________ (name of law firm) or as the case may
be], located at __________ [address], __________ [city],
__________ County, California. The deposition will continue
from day to day until completed.
__________ [If party deponent is not a natural person, add
the following: Deponent is __________ (a corporation organized
and existing under the laws of California or as the case may
be). __________ (Deposing party) intends to examine deponent
about the following matters at deposition: __________ (list
matters on which examination is requested with reasonable
particularity).]
__________ [If deposing party seeks production of any
materials at deposition, add one of the following:]
[EITHER]
Deponent is required to produce at deposition the following
materials at the time and location set forth above: __________
[describe materials with reasonable particularity]
[OR]
Deponent is required to produce at the deposition the materials
described in Exhibit __ attached to this notice and incorporated
by reference.
__________ [If deposing party intends to audio or video
tape deposition in addition to stenographically recording it,
add the following: Pursuant to section 2025(l)(1) of the Code
of Civil Procedure, __________ (deposing party) intends to
record __________ (plaintiff's or defendant's) deposition
stenographically, and by __________ (audio or video) tape.]
__________ [If deposing party intends to use at trial a
video tape of a party deponent who is an expert witness or
treating or consulting physician, add the following: Pursuant
to section 2025(u)(4) of the Code of Civil Procedure, __________
(deposing party) intends to reserve the right to use at trial
the video tape deposition of __________ (plaintiff or
defendant), who is __________ (an expert witness or a treating
or consulting physician) in this case.]
[EITHER]
The parties or attorneys representing parties served with
this notice are: __________ [list parties or counsel served
with notice].
[OR]
The Proof of Service attached to this notice contains a
list of the parties and attorneys on whom this notice has been
served.
Dated __________.
