Rule 2-417.Deposition — Written questions

Instead of sitting across from a witness and asking questions in person, a party can depose someone by written questions submitted through the deposition officer. The process runs on a set clock: the noticing party serves its written questions with the notice of deposition; any other party then has 30 days to serve cross questions; the noticing party has 15 days after that to serve redirect questions; and any party has another 15 days after redirect to serve recross questions. Once the round of questions is complete, the party who noticed the deposition delivers copies of the notice and every question served to the officer, who puts the questions to the deponent, takes down the answers, and prepares and certifies the transcript the same way as in any other deposition.

Because nobody is in the room to object on the spot, the rule builds objections into the same timetable. An objection to the form of a set of questions is waived unless served within the time allowed for the next round of questions, with one exception: objections to recross questions, the last round, must be served within seven days after the recross questions themselves. Whenever a party objects, it has to state the grounds.