Ivy v. Bolin
- Dulce Foster
- 0:24-cv-03425
- U.S. District Court · District of Minnesota
- 2
In Ivy v. Bolin, Judge Foster denied Ivy’s request to appoint a deposition stenographer because the noticing party must pay recording costs.
The ruling directly affected Plaintiff Rashad Ramon Ivy’s request for court-appointed deposition reporting services and declined to require Defendants to pay the recording costs.
What happened
In Ivy v. Bolin, Rashad Ramon Ivy asked the court to appoint a stenographer for depositions he wanted to take. He said transcription companies he contacted refused to work with people representing themselves.
The court explained that litigants do not have a right to court assistance in conducting discovery or obtaining a court reporter. It also said the Federal Rules of Civil Procedure require the party who notices a deposition to pay the recording costs, so the court could not require the defendants to pay them. The court noted that written questions, interrogatories, and requests for admission are alternative discovery methods.
Judge Dulce J. Foster denied Ivy’s Request, ECF No. 77. The order did not appoint a stenographer.
The detailed version
- Ivy v. Bolin · No. 0:24-cv-03425
- Dulce J. Foster
- June 30, 2025
Background
Plaintiff Rashad Ramon Ivy, who was representing himself, submitted a June 24, 2025 letter asking the court to appoint a stenographer for depositions he wished to take. Ivy said that transcription service companies he contacted categorically refused to work with people representing themselves.
Court’s Analysis
The court stated that litigants do not have a right to affirmative assistance from the court in conducting discovery or securing a court reporter. It also relied on Federal Rule of Civil Procedure 30(b)(3)(A), which provides that the party who notices a deposition must pay the recording costs. Because of that rule, the court concluded that it could not require the defendants to bear those expenses.
The court noted that the Federal Rules provide other discovery methods if Ivy lacked the financial resources to obtain oral-deposition reporting services: depositions by written questions under Rule 31, interrogatories to parties under Rule 33, and requests for admission under Rule 36.
Disposition
Judge Dulce J. Foster denied Plaintiff Rashad Ramon Ivy’s Request, ECF No. 77. The order did not appoint a stenographer.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.