Deposition Objections
82 Forms
Before the Deposition
Checklist for Deposition Subpoenas, Notice of Deposition, Deposition Subpoena, Rule 30(b)(6) Deposition Subpoena, Letter Confirming a Deposition, Privilege Log, Protective Order
Checklist of Steps to Take in Preparation for Objecting to a Subpoena or Moving to Quash, Motion to Modify a Subpoena, Motion to Quash a Subpoena, Brief in Support, Affidavit in Support, Declaration in Support, Order Granting
Explaining the Nature of a Deposition, Checklist of Common Objections and Responses
Grounds for Objecting
Checklist: When the Attorney-Client Privilege Does and Does Not Apply, Letter Confirming Joint Defense Agreement, Motion to Compel, Brief in Support, Order Granting, Motion for a Protective Order, 2 Briefs in Support, Letter Confirming Verbal Confidentiality Agreement
Checklist for Privilege Against Self-Incrimination, Motion to Compel Discovery, Brief in Support, Checklist: Do Federal or State Rules of Evidence Apply Re Privileges in Your Case, Checklist of Family Communication Privileges, E-Mail Regarding Resolution of Dispute, Checklist for Making Objections Based on Professional Privileges, Stipulation and Order for Limited Disclosure of Information, Checklist for Preparing to Assert Privacy Objections, Motion for Protective Order, Checklist for Legal Process Objections
Letter to Counsel as to Scope of Deposition Questioning, Motion for Bifurcation of Discovery, Brief in Support, Order Granting
Procedural Issues During the Deposition
Checklist for How to Handle a Telephone Hearing on an Objection to a Deposition Question, Notes as to Dispute Positions, Notice of Motion and Motion on Court Supervision of Depositions
Checklist on Whether to Instruct the Witness Not to Answer, Checklist on Steps to Be Taken Before Adjourning a Deposition, Checklist of Steps to Be Taken in Adjourning the Deposition and Moving for a Protective Order, Motion for a Protective Order, 2 Briefs in Support, 2 Declarations in Support, Order Denying
Checklist on How to Handle Speaking Objections and Witness Coaching, Stipulated Order Prohibiting Coaching, Checklist on Whether You Should Talk to a Witness During a Deposition Break
Checklist on Rules for Deposition Conversations, Checklist of Language for Putting Stipulations on the Record, Letter Confirming Agreement that Each Side Will Bear Its Own Experts’ Deposition Costs, Letter Confirming Central Depository for Original Transcripts and Exhibits, Motion to Preclude Use of Unresponsive Answers to Deposition Questions
Special Situations
Checklist for Laying the Groundwork for the Expert’s Deposition, Checklist Explaining the Objection Process to an Expert Witness, Letter Confirming Agreement that Draft Reports Will Not Be Discoverable, Letter Confirming Agreement as to Payment of Expert Witnesses’ Fees
Checklist on Objecting to Testimony of Witnesses You Do Not Represent, Checklist on Preparing for a Videotape Deposition
Checklist on Preparing to Monitor and Object to the Primary Interpreter’s Conduct, Checklist of Questions to Ask Interpreters or EFL Witnesses About Their Pre-Deposition Communications with Each Other, Checklist on Preparing for Objections to the Translation Process, Checklist of Issues to Be Addressed in Preparing a Protocol for Use of Interpreters at Depositions, Order Governing Use of Interpreters
Scheduling Order with Provisions for Attendance of Non-Parties at Depositions, Checklist on What to Do When an Unauthorized Person Appears at a Deposition, Letter Notifying Opposing Counsel that a Non-Party Witness Will Be Present at a Deposition, Motion to Preclude Non-Party Witness from Attending Depositions
After the Deposition
2 Motions to Compel Deposition Testimony, Brief Opposing Motion to Compel, Affidavit in Support of Motion, Correction Sheet, Motion to Strike Changes, Brief Opposing Motion to Strike Changes
