UNITED STATES DISTRICT COURT
Plaintiff's Motion to take Discovery
FOR THE DISTRICT OF COLUMBIA
William Thomas, et. al. | C.A. No. 94-2742
Plaintiffs pro se, | Judge Charles R. Richey
The United States, et. al. |
MOTION TO TAKE DISCOVERY
BY OTHER THAN STENOGRAPHIC MEANS
The Court recognizes, "Plaintiffs might need additional time to perform discovery". Order, January 11, 1995.
On January 17, 1995 plaintiffs were notified by the Clerk's Office that service of process has been made on most defendants.
Now, it appears the question of discovery is ripe. As
indicated at the January 6, 1995 hearing, plaintiffs are anxious for a factual inquiry into this matter.
This action is before the Court in forma pauperis, a factor which, without the Court's assistance, might pose unnecessary delays in conducting discovery.
Fed.R.Civ.P 30(b)(4) provides for situations where a
depositions may to be recorded by other than stenographic means:
"The parties may stipulate in writing or the court may upon
motion order that the testimony at a deposition be recorded by other than stenographic means."
"The rule clearly contemplates only two methods for non-stenographic recording of a deposition: the parties must either stipulate in writing to some other method, i.e., electronic recording, videotaping, etc, or the party seeking discovery must move the court to order some other method." Westmoreland v. CBS, 770 F.2D 1168, 1175.
A proposed Order is attached.
Respectfully submitted this _____day of January, 1995,
William Thomas, Plaintiff pro se
2817 11th Street N.W.
Washington, D.C. 20001
CERTIFICATE OF SERVICE
I hereby state that, on January __, 1995, I served copies of
the foregoing Motion to take Discovery by Other than Stenographic
Means upon the office of the United States Attorney for the
District of Columbia at 555 4th Street NW, Washington, D.C.