“Apex” Depositions of High Government Officials Under the “Morgan” Doctrine
E-Discovery LLC
MAY 20, 2025
When ruling on protective orders for executive depositions, courts generally ask whether: (1) the official has unique personal knowledge of the disputed matter; (2) the information can be collected through less intrusive discovery methods; and (3) the deposition unduly interferes with the officer’s professional duties. Lederman v.
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