1. Objecting to Deposition Notices and Subpoenas
2. Motions to Quash or Limit Deposition Subpoenas
3. Preparing Witnesses for Deposition Objections
II. GROUNDS FOR OBJECTING TO DEPOSITION QUESTIONS
A.
Objections Based on Privilege and Confidentiality
4. Attorney-Client Privilege
5. Attorney Work Product Privilege
6. Proprietary and Confidential Information
7. Witness Self-Incrimination
8. Family Communications Privileges
9. Privileges for Communications With Professionals
10. Privacy Privilege
11. Legal Process Privileges: Law Enforcement Records,
Deliberative Process, Settlement Discussions
B.
Objection Based on Other Grounds
12. Relevance: Overbroad and Burdensome Questions
13. Vagueness, Ambiguity, Repetition, and Lack of
Foundation
14. Legal Conclusions
III. PROCEDURAL ISSUES DURING THE DEPOSITION
15. Court Rulings and Supervision During a Deposition
16. Instructing the Witness Not to Answer a Question
17. Coaching and Communications with the Witness During
Breaks
18. Colloquies and Stipulations Among Counsel
19. Motions to Strike and Clarification of Testimony
IV. SPECIAL SITUATIONS
20. Objections at Expert Witness Depositions
21. Objections to Testimony of Witnesses You Do Not
Represent
22. Objections to Videotape Depositions
23. Objections at Depositions of Non-English Speaking
Witnesses
24. Objections to Attendance of Unauthorized Persons
V. AFTER THE DEPOSITION
25. Making and Opposing Motions to Compel Deposition
Testimony
26. Reviewing and Correcting the Deposition Transcript
