If the name of a non-party deponent is not known, what must be provided?

• A. A description sufficient enough to identify the person or particular class/group to which the person belongs
• B. The deponent's phone number
• C. A published registry listing
• D. A letter of recommendation

Answer: (A)

When a subpoena is issued to a non-party for a deposition and you don’t know the witness’s name, you must describe the witness sufficiently to identify the person or the class they belong to. This descriptive identification lets the recipient understand who should be examined or located and how to find the right individual, such as naming a job title, role, or the group within an organization (for example, “the custodian of records for Acme Corp” or “the person who negotiated the contract on behalf of Acme Corp during 2023”). The purpose is to ensure the deposition can proceed even without a named individual by pointing to the right person or category of persons. A phone number, a registry listing, or a letter of recommendation do not satisfy this identification requirement.