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Deposition DON'Ts: Guess or speculate. ?I don't know? or ?I can't remember? is acceptable. Be anxious or stressed out. It will affect what you say and how you appear. Be defensive or angry. Never argue with the attorney. Offer information not requested. ... Talk too much or ramble. ... Talk too little. ... Be too extreme.
Discovery means you send the other side questions and requests for information or items (like documents) in writing. The other side must respond to your question or request in writing.
You will hand a document to the court reporter, and have him or her mark the exhibit, starting with 1 or A. Generally, you'd ask, ?Please mark this document as Exhibit A,? or something along those lines. You can premark the exhibits if you prefer to save time.
5 Steps for Responding to a Deposition Notice Analyze the documents that were served. ... Notify the party deponent. ... Decide whether to contact a nonparty witness. ... Object to defects in the deposition notice. ... Object to the production demand.
What Needs to Be in Your Notice of Deposition? The names, addresses, email addresses, attorney bar numbers, and telephone numbers of each attorney and who they represent. The type of deposition notice should be characterized in the document title. ... The date, time, and location where the questioning will occur.
At this point, the court reporter will administer an oath to the deponent. After that, you can dig into your outline with the standard opening question, "Please state your name for the record," or, if you want to sound like an old pro, "Tell us your name, please."
Rule 2-412 - Deposition-Notice (a) Generally. A party desiring to take a deposition shall serve a notice of deposition upon oral examination at least ten days before the date of the deposition or a notice of deposition upon written questions in ance with Rule 2-417.
In other words, if you wish to compel the party deponent to bring documents, the deposition cannot be noticed to occur for at least 30 days. The Northern District local rules require conferring with opposing counsel before sending out a notice of a party.