Objections and Responses to Notice of Deposition
(OH)

Summary

This template objections and responses to a notice of deposition can be used in an Ohio state court civil case. It includes practical guidance, drafting notes, and alternate clauses. A party who wants to take an oral deposition must give "reasonable notice in writing" to every other party to the action. Ohio Civ. R. 30(B)(1). You may object to the notice if it does not state the required information, such as when, where, and how the examination will take place. While these objections are not required, they memorialize the entity's positions and can facilitate a resolution prior to the deposition. These sample objections assume that the plaintiff is the deposing party; reverse the party designations and some of the language in the template if a defendant is the deposing party. This template is designed for objections to a notice of deposition that seeks to depose a named individual, not a notice of deposition that seeks to depose a corporate, government, or other similar entity under Ohio Civ. R. 30(B)(5). For objections to a 30(B)(5) deposition, see Objections and Responses to Notice of Rule 30(B)(5) Deposition (OH). For more on the notice of deposition and depositions generally, see Depositions: Drafting and Serving a Notice of Deposition (OH), Depositions: Defending an Individual's Deposition (OH), and Deposition Objections Checklist (OH).