The "usual stipulations" where I practice actually does have meaning. It relates to preserving objections, except as to the form of the question, until the deposition is sought to be used in court, so what may ultimately turn out to be a discovery deposition never used at trial does not needlessly become a battlefield strewn with evidentiary objections. No doubt it is different where Mr. Hayes practices and in other jurisdictions.

Hahaha. That takes me back a few years.

I actually did ask what they were at my first deposition and was told that all objections except as to the form of the question were waived. And thereafter I always put that on the record, as well.

Notwithstanding that stipulation, deponents' lawyers seemed to be forever making inappropriate objections, following which I would equably instruct the deponent "You can answer", thus creating a thoroughly confusing tableau for the deponent that often resulted in eliciting responses far more revealing and candid than perhaps would have otherwise been the case had deponent's counsel kept his own counsel.

A few years afterwards, Judge Fullam issued his renowned "potted plant" ruling on how deponents' counsel should behave at depositions.

As usual, Hayes's reading of the rules is accurate and right on that pursuant to those rules there are no usual "stipulations" There are, as he points out rules governing depositions with default positions. My experience from long ago was when lawyers agreed to the usual stipulations that the court reporter would write in the stipulations that (s)he thought were usual as matters of stipulation. The best practice is to state the stipulations you want. The stipulation regarding objections is helpful as the rules are unclear as to what objections must be made to be preserved. Although not a matter of stipulation either party or the witness can require the reading and signing of the deposition during which (according to the rules) making clerical and substantive changes with a reason for the change in the deposition is required. The default position of the rules on reading and signing is that absent the demand of any party or the witness, the reading and siogning (and therefore correcting) is waived.

I understand it may vary from state to state and am curious whether there is an actual rule which explicitly references "usual" stips and what they are.