MEMORANDUM OPINION AND ORDER

HENRY PITMAN, Magistrate Judge

By notice of motion dated July 19, 2004, the plaintiff in this inmate civil rights action moves to compel certain discovery. Specifically, plaintiff seeks to compel the production of documents and to take the depositions of other inmates who may have knowledge relevant to plaintiff's claims. The motion is granted in part and denied in part.

The plaintiff in this action alleges in substance that he was subjected to retaliation by defendants for his refusal to cooperate with correctional officials concerning certain matters and that defendants failed to protect him against known, objective risks. The defendants have denied all the material allegations of the complaint.

To the extent that plaintiff's motion seeks the production of documents, defendants' response appears to state that the documents in issue have been produced. Plaintiff is directed to write to my chambers within twenty (20) days of his receipt of this Order and advise whether he is still claiming that defendants have failed to respond properly to his discovery requests. If plaintiff claims that documents are still missing, he is directed to identify those documents with as much specificity as possible and explain why he believes the documents exist. An unsubstantiated, generalized belief that defendants are withholding documents will not provide a basis for further relief.

Plaintiff's request to conduct the depositions of other inmates is more troublesome. Plaintiff seeks to depose seven inmates who plaintiff believes have testimony that will support plaintiff's claims. In support of his application, plaintiff has submitted statements from six other inmates, four of which are affidavits, setting forth facts which, if true, would tend substantiate plaintiff's allegations. For example, one inmate states under oath that he was solicited by defendant Surber to start a fire in plaintiff's cell in order to destroy plaintiff's property.

Defendants' entire response to this aspect of plaintiff's motion consists of the following statement: "plaintiff's taking [depositions] of the inmate witnesses would cause DOCS security concerns and would disrupt the order and effective functioning of the correctional facility, and would jeopardize institutional safety and correctional goals and the safety of staff and inmates" (Letter of Assistant Attorney General Nicola N. Grey, dated July 27, 2004, at 2).

The problem with defendants' position is that it is based on generalizations that are applicable whenever an inmate seeks to depose another inmate and would effectively precludepro se inmates from ever taking the depositions of other inmates. Although I have no doubt that there are often valid reasons for correctional authorities to separate inmates or to prevent them from communicating with each other, an across-the-board prohibition against inmate-conducted depositions of other inmates based on generalized concerns that may or may not be applicable in this particular case is an overly-broad remedy. In addition, given that the only possible witnesses in many inmate civil rights cases will be either corrections officers or inmates and given the additional fact that the vast majority of inmate civil rights litigation in this District is conducted by plaintiffs proceeding pro se, the broad prohibition sought by defendants would have the effect of limiting the testimony in most inmate cases to that of the corrections officers and the plaintiff. If a lawsuit is to be a "search for truth," Polaroid Corp. v. Casselman, 213 F. Supp. 379, 381 (S.D.N.Y. 1962), discovery should maximize the litigants' access to all sources of probative evidence, with appropriate consideration given to the factors that might justify the issuance of a protective order limiting discovery in a particular case. The written statements submitted by plaintiff establishing that at least six of his potential witnesses have information which, if true, bears on his claims, is compelling evidence that plaintiff is proceeding in good faith and with good cause. The burden on the Department of Correctional Services and any security risk can be minimized by directing that the depositions be conducted by written questions or by telephone, with the testimony tape recorded.

There are, however, other practical issues which the parties' papers do not address. For example, the cost of a deposition is ordinarily borne by the party taking the deposition. He or she bears the financial burden of making a tape-recording, making the conference call necessary to conduct the deposition and paying the fee of the individual who administers the oath. The court has no funds to pay these expenses, and the fact that plaintiff lacks the funds to pay these fees is not a basis to shift them to the defendant. Given plaintiff's poverty, it is not clear that he is able to pay these fees.

If plaintiff wishes to proceed with the depositions he seeks, within twenty (20) days of the date of this Order, he is to submit a proposed plan for conducting the depositions he seeks. The proposal should address how the depositions will be conducted and, if they are to be tape-recorded, who will provide the tape and the tape recorder, who will pay for the conference call and who will administer the oath. In addition, plaintiff should also bear in mind that any tape-recorded deposition will need to be transcribed, at plaintiff's expense before it can be used in court; untranscribed tapes cannot be submitted to court. Defendants shall have twenty (20) days to respond to plaintiff's submission. Plaintiff should also consider whether it would be more practical to conduct the depositions by written questions. The procedure would permit plaintiff to mail written questions to the witnesses which they would then answer under oath. Defendants would have the right to "cross-examine" by written questions. For the convenience of the parties, copies of Fed.R.Civ.P. 30 and 31 are attached to his Order.

In addition, because there may be some specific problems with the depositions plaintiff seeks that have either arisen since the date of his motion or that were inadvertently over-looked by defendants' counsel, defendants shall have twenty (20) days from the date of this Order to identify any specific problems with the depositions sought by plaintiff.

The schedule for the completion of discovery shall be adjusted appropriately upon the final resolution of plaintiff's application to take depositions.

Conclusion

For all the foregoing reasons, plaintiff's application to compel the production of documents is denied without prejudice to renewal if there are still documents in dispute. Plaintiff's application to conduct depositions of other inmates is granted in part, subject to the parties' supplemental submissions described above.

SO ORDERED.