Scheduling

Setting a date that holds

Most blown deposition dates fail on notice mechanics, not on the merits. The periods, contents, and objection windows that keep a date set.

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Notice periods

How much lead time each forum needs

Minimums, not targets — short-notice dates happen, but they need agreement or a cooperative calendar.

California: 10 days after service

CCP 2025.270(a) counts from service, and the service method extends the clock — mail, overnight, and out-of-state service each add their own time. Objections generally due 3 calendar days before.

Texas: reasonable notice

No fixed day count in TRCP 199.2(a) — reasonable under the circumstances, with time-and-place fights stayed automatically if moved on by the 3rd business day after service.

Georgia and Washington

Georgia: reasonable written notice (9-11-30(b)(1)). Washington: at least 5 days, 20 for video-recorded depositions (CR 30(b)). Federal: reasonable written notice (FRCP 30(b)(1)).

Booking well

What makes a date easy to cover

The agency side of the same problem: everything the reporter needs to say yes quickly.

The notice itself

Caption, date, venue or platform, witness, matter type, recording method, and any remote-means statement. A notice with all of it books in one round trip.

The protective order, early

Source code and attorneys'-eyes-only orders change binding, delivery, realtime availability, and room requirements. Reading it late compresses all of that.

Length and tier up front

Expected testimony length, realtime needs, and turnaround tier determine staffing and price. Decided at booking, they are planning inputs; decided later, they are change orders.

Scheduling questions

Notice, objections, and booking

How much notice does a deposition require?

It depends on the forum. California requires at least 10 days after service of the notice (CCP 2025.270(a)), and the service method can extend the lead time — confirm the arithmetic before booking. Texas requires reasonable notice with no fixed day count (TRCP 199.2(a)). Georgia requires reasonable written notice (O.C.G.A. 9-11-30(b)(1)). Washington requires at least 5 days written notice, and 20 days where the deposition will be video-recorded (CR 30(b)(1), (b)(8)(A)). Federal depositions need reasonable written notice (FRCP 30(b)(1)).

What must the notice contain?

Time and place, the deponent (name and address, or a class description), and the recording method. For an organization, describe the matters with reasonable particularity so it can designate prepared witnesses. If the deposition will be remote, say so and identify the means — Texas requires it in the notice (TRCP 199.2(b)(3)), and California practice puts remote-appearance mechanics in writing under CRC 3.1010.

How do objections and protective orders work on short timelines?

California waives most irregularities unless objected to in writing at least 3 calendar days before the date (CCP 2025.410(a)). Texas stays time-and-place disputes automatically when a protective-order or quash motion is filed by the 3rd business day after service (TRCP 199.4). Washington requires a remote-mode objection by motion within 3 days of receiving notice. Georgia has no fixed counter-notice window — move for a protective order for good cause (9-11-26(c)), and object to a nonparty subpoena in writing within 10 days of service.

Can the deposition be noticed remote without asking the court?

In Washington, yes — any party may notice remote without leave of court since the 2024 amendments. In Texas, yes on reasonable prior written notice stating the means. In California, the noticing party arranges equivalent remote participation, with written remote-appearance notices due 5 court days out. In Georgia, no — remote depositions require party stipulation or court order (O.C.G.A. 9-11-30(b)(4)).

What should we send the reporting agency with the date?

The caption, the date and start time, the venue or platform, the witness name, and the matter type. Add the notice itself, any protective order, and the expected length and turnaround tier. For technical matters, pleadings, asserted patents, and expert reports up front let the reporter build the terminology glossary before the date instead of repairing the transcript after it.

What if the schedule moves after booking?

Tell the agency as early as the court tells you. Reporter assignment, realtime setup, travel, and videography all key off the date — and cancellation terms travel with the written quote, so moving early is always cheaper than moving late.