Pro Se Depositions in Divorce

by Danny
(Pensacola)

As a Pro Se litigant in a contested divorce, what steps do I need to take to depose my spouse? I served interrogatories on November 22nd, 2021, and my spouse has yet to answer them, so my next attempt at discovery is deposition by oral examination.

Here’s what I know:

Any party can take the oral depositions of anyone, including a party.

I need to file a Notice of Taking Deposition, which will include the date/time/and location the deposition will take place.

I must notify all parties to the case at least 14 days (preferably more) before the deposition.

Here’s what I’m unsure about:

Do I need to file any sort of motion in order to take the deposition, or just the Notice?

How do I ensure that the audio recording of the deposition will be admissible in court? Do I need to immediately give the other party a copy of the tape? Or establish some sort of chain of custody?

Thanks in advance, DC