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PREPARING FOR THE DEPOSITION
THE TOOLS OF DISCOVERY
MATTERS TO CONSIDER BEFORE THE DEP
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30 days admissible adversary adversary's adverse party Affirmative Designations Answer 2 Q3 asked attorney-client privilege attorney's Changes at Trial Civil Procedure client court order court reporter Cross-Designations defending attorney deponent deponent's deposing attorney Deposing Party's Deposition at Trial deposition questions deposition testimony deposition transcript discovery documents ensure evidence at trial examining attorney expert witness facts fairness designations Fed.R Fed.R.Civ Fed.R.Civ.P Fed.R.Evid Federal Rule 26(bXl filed follow-up Form Identical to Federal impeachment instruction interaction interrogatories issue Judicial Relief Letter Rogatory litigation monitor motion to compel non-party witness Non-verbal Communication Non-verbal Cues notice of deposition objection officer oral deposition person Plaintiff Post-Deposition presenting attorney prior proper protecting attorney protective order Q3 Possible Answer reasons relevant Requests to Admit requires response Rule of Civil sanctions scope seek served specify statement stipulation strategy subpoena subpoena duces tecum substantive take the deposition taken testify unavailable understand waive signature waiver work-product doctrine written depositions