Taking a deposition of an uncooperative witness in a foreign country may be complicated. See Williams, Taking Depositions Abroad, Los Angeles Lawyer 10 (December 2005), located by searching the Los Angeles County Bar Association website at www.lacba.org. The text of the "Hague Convention of 18 March 1970 on the Taking of Evidence Abroad in Civil or Commercial Matters" and a "Model for Letters of Request" can be found on the Hague Conference on Private International Law website. Important information about the Hague Convention, the preparation of letters rogatory with samples, and country specific information is also published on the U.S. State Department website at http://travel.state.gov on the Law & Policy page, under the Judicial Assistance menu. Additional important information can be found in the State Department's Foreign Affairs Manual, particularly 7 FAM 920 ("Taking Voluntary Depositions of Willing Witnesses") and 930 ("Compulsion of Evidence"), available on the U.S. Department of State’s website at www.state.gov.
Local Rules of Civil Procedure
LR 28 - Depositions in a Foreign Country