Deposition Objections

Here is a quick-draw armory of dozens of objections and tactics to help you protect your witness and your case, including: attorney-client privilege, attorney work-product, proprietary and confidential information, witness self-incrimination, family communications, communications with professionals, privacy, legal process privileges, relevance, vagueness, ambiguity, repetition, lack of foundation, legal conclusions, and more.

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Deposition Objections gives you dozens of objections and tactics for confronting and resolving contentious deposition disputes. This edition adds new text, tips, and approximately 100 new cases to help you protect your witness and your case. Revisions and additions include:

Chapter 1 OBJECTING TO DEPOSITION NOTICES AND SUBPOENAS

Proportionality (§1:80, 1:81):

  • In 2015, the Federal Rules of Civil Procedure were amended to require that discovery be proportional to the needs of the case—which had a major impact on the scope of permissible deposition objections. This edition describes how courts are applying proportionality and how you can use this new law to make or oppose objections more effectively.

CHAPTER 10 • RELEVANCE: PRIVACY PRIVILEGE

Recent Changes in the Law of Privacy:

  • The Dobbs decision and LGTBQ+ Matters (§§10:02, 10:06-10:07): The U.S. Supreme Court’s 2022
    Dobbs decision upended not only American abortion law but the law of privacy, particularly for litigants
    who want confidentiality as to matters concerning sex and gender identification or who want to obtain such
    information. This edition provides tools to navigate these sensitive issues when they arise during depositions.
  • Internet Matters (§ 10:05): New developments in internet information collection technology and how to
    handle requests for such information.
  • COVID Vaccination (§ 10.08)

CHAPTER 22 ∙ OBJECTIONS TO VIDEOTAPE AND REMOTE DEPOSITIONS

Remote Depositions Before and After COVID (§22:20-22:22):

  • Remote depositions were rare before 2020, but they became essential during the COVID-19 pandemic and they have remained popular since the epidemic’s end. This edition explains how you can arrange remote depositions and use objections at such depositions to protect your client’s interests.

And More!

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